Permanent/occasional trade character decisive for RRM designation in complex delegation chains
- Category: REMIT
Establishing circumstances where the RRM designation by the wholesale energy market participant is required, and where it is not, is almost entirely governed by ACER's frequently changing interpretations.
This is not a comfortable situation from legal certainty point of view. If these interpretations were a little bit clearer...
Brokers as reporting agents under REMIT
- Category: REMIT
Brokers role in the REMIT reporting framework appears somewhat complex. Let alone entirely different structuring of executing brokers and the clearing ones (where the clearing brokers have been placed - fundamentally - outside the REMIT market participants' scope), the reporting of life-cycle events with respect to trades executed with the broker's participation requires a careful reflection.
Another problematic case emerges when the firm has two different types of business - is an executing broker (exchange member) and is also an organised market place (it runs a broker platform). Recent updates to the ACER's reporting manuals offer some help while resolving these issues.
Benefits from trade repositories having an RRM functionality - areas for residual risk
- Category: REMIT
Are you completely certain on what occasions your energy supply and derivatives contracts must be reported to ACER and not to the trade repository?
Surprised? It may mean you are at risk of non-compliance...
Client relationship brings bonuses under REMIT
- Category: REMIT
As the latest version of the ACER's reporting guidelines acknowledges, the client participation in the trading venue not involving a membership does not entail a reporting requirement for the client under REMIT.
Day-ahead contract is a "forward style"?
- Category: REMIT
Do you identify differences between "forward contract" and "forward style contract"? No? You should start doing this. Since "forward style contract" can equally be a spot and your REMIT transaction reports may occur flawed.
Our REMIT magnifying glass - check whether your transparency website uses RSS feed!
- Category: REMIT
There are first regulatory interventions sanctioning improper disclosure of REMIT inside information, in particular, regarding the power plant unplanned unavailability.
It shouldn't be a surprise since the necessary content of such disclosure is sometimes missing.
The key dates approaching are 7 April 2016 and 7 July 2016.
10 MW REMIT reporting threshold - manageable by the way of contracting
- Category: REMIT
In determining whether the electricity production facility is able to make use of the de-minimis exemption from the REMIT reporting requirement the three elements are relevant:
(1) spatial proximity (whether installations are spatially separated)
(2) ownership structure, and
(3) marketing for several smaller installations in one common contract/multiple contracts.
RRM designation when first registering under REMIT - complicated case
- Category: REMIT
The latest version of a ACER's Questions and Answers on REMIT brings once more some important novelties of crucial practical importance.
However, one may still feel confused what is the clear requirement with respect to Registered Reporting Mechanism (RRM) designation when first registering with CEREMP.
ACER's common schema for REMIT publications - carbon impact and "decision time" included
- Category: REMIT
ACER recommends, REMIT publication schema should include, among others, the field "impact on carbon permit prices" as well as "decision time" in order to allow users to evaluate the timeliness of the disclosure.
Financially-settled energy products traded outside the EU also to be reported under REMIT
- Category: REMIT
If a person enters into a transaction on a derivative contract related to EU gas and electricity (such as a futures contract only for financial settlement that is traded on exchange located outside the EU), that person is not a REMIT market participant.
However, according to the European energy market regulator, if that person also enters into transactions, including the placing of orders to trade, in one or more wholesale energy markets, e.g. enters on a physical trade (or derivative) for the delivery of gas or electricity (or transportation of gas or electricity) within the EU, that person is a market participant and has to report all the transactions on wholesale energy products including those trades outside the EU that are only for financial settlement.
This interpretation imposes REMIT reporting requirements on the - quite extensive - category of extra-EU financial derivatives trades and counterparties.
REMIT reporting approaches...
- Category: REMIT
So, given that the final TRUM is already adopted and published, the key point for any engaged in energy trading is now to establish whether:
(1) the trading platform at issue qualifies as an "organised market place", and
(2) the contract at issue is a "standard contract" or a "non-standard" one.
While the former determination looks like not so difficult (but, sometimes, surprising), the latter appears quite a complex task.
Finally, the identification of "non-standard contracts specifying at least an outright volume and price" (for which specific reporting rules apply) is really a puzzle!
Intragroup brokers - need to bother for REMIT reporting?
- Category: REMIT
Do the intragroup brokers qualify as organised market places for REMIT reporting purposes and what are potential consequences?
REMIT reporting rules settled
- Category: REMIT
REMIT Implementing Regulation specifying responsibilities' allocation for power and gas transactions' and orders' reporting has gone through the comitology procedure and awaits for adoption by the European Commission.
Emissions-EUETS.com has looked into details of the new reporting scheme.
Nuances of REMIT and EMIR reporting
- Category: REMIT
Intra-group transactions and orders' reporting are areas where both schemes should not be commuted for...
ACER code vs. LEI - which one more important?
- Category: REMIT
It appears from the latest embodiment of the REMIT draft Trade Reporting User Manual (TRUM) that in the REMIT compliance system ACER code and the LEI may be used interchangeably.
How the REMIT compliance system should look like?
- Category: REMIT
It appears, energy regulators have gathered sufficient knowledge, and are keen now to acquire experience in practical aspects of REMIT functioning.
Recent Ofgem communication indicated the regulators' key areas of interest for REMIT compliance checking.
RRM conception crystallised
- Category: REMIT
Market participants may choose either to become an RRM themselves or to use one or more third party RRMs to submit transaction reports to the ACER.
ACER's list of standardised and non-standardised contracts - indispensable tool for wholesale energy market players
- Category: REMIT
From practical point of view the important task for market participant when it comes to REMIT reporting will be the qualification whether the contract is standardised or not.
The ACER' list of standardised wholesale energy contracts would specify types of contracts for which standard reporting is mandatory.
Decisive for the reporting as standardised or non-standardised contract will be the fact whether a contract is or is not listed in the Agency's REMIT database.
All non-listed energy commodity contracts would be considered non-standardised and are to be reported with the non-standard reporting form, but including a copy of the contract as such in order to enable the Agency to revert to it in the market monitoring of wholesale energy markets in case of suspicious behaviours.