ACER have updated their Questions and Answers document on REMIT which can be found here. There are three new answers and one updated one:
If a holding owns several market participants but is not one itself, nominates one to act as the RRM for the others, but the holdings do not have any employees, who is responsible for the reporting and how should the RRM application form be filled (III.2.47, page 50) – In terms of responsibility, the provisions of the REMIT Implementing Act Article 11(2) apply, i.e. that once data is correctly given to the RRM entity it is responsible for data submission, but the original entity shall take reasonable steps to verify the completeness, accuracy and timeliness of the data.
How should an RRM or RRM applicant ask questions about the Contingency plan (III.2.48, page 51) – They should email email@example.com
[Updated] Explain which country’s calendar should be used when establishing the deadline for reporting data on the “working day following the conclusion of the contract or placement of the order” (III.3.27 page 60) – The calendar of the country of the market participant should be used. The link to the official list of public holidays in the Q+A has been updated to: http://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=uriserv:OJ.C_.2014.463.01.0017.01.ENG&toc=OJ:C:2014:463:TOC).
A scenario is described where Company A and Company B are market participants, and Company C is a final customer. B has a contract to supply C. B enters into a contract with A, such that A supplies the energy directly to C, but there is no contract between A and C. Is the contract between A and B reportable (III.3.39, page 66) – Yes that contract is reportable.
No updates have been made to the transaction reporting FAQ.