For market participants with physical assets, "person responsible for operational decisions" should be "the person who is responsible for decisions relating to the running of these assets". And for market participants who don't possess such assets?
Market participants' registration under REMIT has been ignited in December, hence it can be expected those engaged in trading in wholesale energy products will spend the following weeks studying registration manuals.
The said instructions seem relatively well and comprehensively written, so, overall, there shouldn't be much trouble with the registration.
Certain points will, however, deserve greater attention. This the case, particularly, with the manual's section requiring every market participant registering with CEREMP to provide details for each of the three positions in the market participant's organisation:
- Contact for REMIT communications,
- Person responsible for trading decisions [not individual traders],
- Person responsible for operational decisions.
The precise distinction between the categories of persons to which the responsibility for trading and operation decisions have been attached, within some organisations may rise doubts, as theese areas of competencies are not always clearly separated.
The REMIT registration manual comments upon these points that the functions of e.g. the "Head of Trading" and the "Head of Operations" are, respectively, meant, and in both cases the "ultimate" responsibility should be indicated in the CEREMP fields.
As regards the person responsible for operational decisions one more key guideline has been given, namely that for market participants with physical assets, this should be the person who is responsible for decisions relating to the running of these assets.
So, it appears at least for energy producers having generation units the issue became more clear.
However, the greatest concern with these points can potentially be within large corporate groups where operational and, notably, trading decisions often represent an outcome of sophisticated, not to say - Byzantine, processess and procedures, and unequivocal indication of only one person responsible, as REMIT registration rules require, may sometimes be questioned.