We are now in the week during which the second phase on REMIT reporting starts, this Thursday 7th April. From that day, any qualifying “off venue” activity under REMIT must be reported by market participants to ACER using an RRM (or by the participant becoming an RRM themselves).

There have been many updates issued by ACER in the last few weeks, starting on 16th February at the same time as the public workshop (notes here), an update to the REMIT Questions and Answers (notes here) and transaction reporting FAQ, and also last Friday with a new document on the reporting of fundamental data.

The relatively late issue of these documents has given cause for  some to struggle to meet these deadlines. However it should be noted that April 7th is only the first of several milestones, and that only some data needs to be reported from then:

• “Standard contracts” which are OTC versions of on venue transactions must be reported within a day of execution – i.e. from April 8th.
• “Non Standard contracts” need to be reported within one month of execution – so the first possible deadline is in May.
• “Back-loaded” contracts, i.e. those already open on April 7th, only need to be reported within 90 days of April 7th.

Many contracts will fall into the last two categories, and so in many ways this is a phased roll out. However, fundamental data relating to gas balances in store, and LNG unloads and reloads need to be reported within a working day, and planned LNG unloads and reloads need to be reported before the activity commences.

Whether phased or not, many market participants will have something to report this week.  Hopefully all will be ready.