ACER have published an updated version of the REMIT Questions and Answers document, with two new entries. The document can be found here.
The first of the new entries is question II.4.47 on page 28 and relates to market participants who have not yet registered in the CEREMP (Central European Registry of Energy Market Participants). Registration is required before entering into a “reportable transaction”, making the deadline for registration either on the 7th October 2015 or 7th April 2016 for covered market participants. The questions asks what a market participant should do if this deadline was missed. The answer given is that missing such a deadline is a breach of REMIT and sanctions could well be applied to the market participant by the relevant National Regulatory Authority (NRA). It does not state what such a market participant should actually do if they find themselves in such a situation.
The other entry is question III.3.40 on page 65. This relates to upstream gas capacity defined as “any pipeline or network of pipelines operated and/or constructed as part of an oil or gas production project, or used to convey natural gas from one or more such projects to a processing plant or terminal or final coastal landing terminal“. The answer states that such transactions are not reportable.
With the “backloading” deadline approaching on 6th July, the message from the Q+A is that any market participants who have not still not registered, or indeed started to report, should do so as soon as possible.