ACER published the 5th version of the transaction reporting FAQ on Monday 26th September, which can be found here. It contains some interesting guidance which can be summarised as follows (3.1.18, 4.1.3 and 4.2.19 added in update):
Q 1.1.20 [P19]: Please provide further guidance on the distinction between bilateral contracts considered to be “standard”(and reported within T+1 day), and those that are considered non-standard. (and must be reported within T+1 month). A: Where the parties “do “not have certainty” that the contract is equivalent to an on venue one, they may assume that a level of customisation exists, and the contract is therefore non-standard and can be reported by the later deadline.
Q 1.1.21 [p19]: If a single contract exists between one counterparty, A, and a group of counterparties, B, C and D, where there is one production unit with several generation units. Only one price and volume is invoiced per month. Which ACER code should be used for the counterparty? A: The reporting party has to allocate the delivered volume to the respective contracts (counterparties) and report as many transactions as the number of counterparties.
Q 2.1.4 [p24]: Under which circumstances does the TraderID field number 3, of table 1, need to be filled in for off venue trades? A: the field should be populated for all OTC trades, but not when using table 1 for executions linked to a “table 2”.
Q 3.1.17 [p94]: What does one do if one does not have the agreed UTI by the time the trade is reported? A: Use a temporary UTI and then send a new one, using specific “UTI change” tags in the latest schema for table 1, version 2 issued in late July.
Q3.1.18 [p96]: If a contract/trade for optional physical delivery includes a “service fee premium”, should the premium be reported? A: No.
Q3.1.19 [p97]: How does one report a contract which embeds delivery to multiple TSOs and how are they backloaded? A: A different report must be submitted for each TSO. Backloading follows the usual rule that if the trade was executed before 7th April 2016 and still in delivery on that date, it must be reported by 6th July 2016.
Q3.1.20 [p98]: Is a Hydro Storage Virtual power Plant deal reportable? A: Yes, if it is possible for physical delivery to result from the contract.
Q3.2.7 [p105]: Does field 24 of table 2 (Type of index price) always need to be filled in? A: No, it is not a mandatory field and does not need to be filled in when not relevant.
Q: 3.2.9 [p105]: Do FX embedded indices need to be reported? : A: No, only indices relating to the fixing of the energy commodity price, including oil and coal.
Q: 3.4.6 [p115]: If several contracts are invoiced together, for example where they are transacted with the same joint venture where one party handles the invoices, how should they be reported? A: Each contract and execution should be reported separately.
Q3.5.5. [p118]: Do intra-day changes to an OTC deal need to be reported? A: Yes each change should be reported as a lifecycle event.
Q4.1.3 [p121]: What is the timeframe for reporting secondary transportation contracts? A: All secondary transportation contracts should be reported within one month.
Q4.2.19 [p135]: If transportation capacity is bundled together with a beach gas purchase need to be reported? A: No, since only transportation between two delivery points needs to be reported.
Some of these answer will surprise market participants, but many do provide clarity on specific issues.