There is now one week to go until April 7th, the date on which off venue reporting under REMIT starts. From that day, trades and contracts covered by REMIT must be sent to ACER either within a day or a month of being struck, depending on their status. Market participants also need to send some types of fundamental data, relating to gas balances in store and LNG unloads and reloads. Trades and contract that are “open” on the 7th need to be backloaded within 90 days.
There have been many unanswered questions on how to report, especially on tables 3 and 4 and on fundamental data. A week ago, ACER released several updated documents including a new version of the transaction reporting FAQ and REMIT Q+A (notes on the Q+A can be found here). The transaction reporting FAQ contained, for the first time, several answers on tables 3 and 4, but not fundamental data. Market participants do not have very long to assimilate the information.
Much of the data for this phase, especially framework contracts, will have “backload” status, whose deadline is further away. Never the less, many will struggle to meet next week’s deadline. For example “Look alike” standard trades transacted on the 7th will need to be reported on the 8th. There is therefore much work to do for many.