See here for an article on the ICIS web site which discusses the issues surrounding the reporting of LNG under REMIT. While LNG is explicitly mentioned in the Implementing Act for fundamental data reporting, there is no such explicit mention in the rest of the Act. However, as a form of gas, there has been some divergence in view on the degree to which LNG is reportable.

The Questions and Answers document of 16th February sees ACER answering that all LNG trades where supply is to be in the union, should be reported. As can be seen from the article, this has some important ramifications. It also opens several new questions about the meaning of “supply into the union” and at which point this takes place. Such questions are likely to remain open for some time.

In many cases, counterparties to such trades may reside outside of the Union. The application of REMIT applies when supply is in the union, regardless of the location of the counterparty, who is in any case required to register and report. However, a provision has now been made so that in the event of a counterparty not being registered, the other party can still report the trade using a special code, as outlined in the latest Transaction Reporting FAQ question 2.6.1 on page 75. This is a possible occurrence with an LNG supply contract.