|ACER Registration Code|
|Internal Electricity Market Glossary|
ACER Registration Code within the REMIT Regulation compliance system means a numerical (alphanumeric, 12 values, example: 1234567890ab) wholesale energy market participant unique identifier assigned by the European Agency for the Cooperation of Energy Regulators (ACER) during the market participant registration process with the EU Member State National Energy Regulator (NRA).
ACER Registration Code is used for REMIT transactions and orders reporting purposes.
Considering the variety of identifiers used (examples: Legal Entity Identifier (LEI), Bank Identifier Code (BIC), Energy Identification Code (EIC), Global Location Number (GLN/GS1)), it is important to note, only registration of market participant with the relevant NRA will result in an ACER code assignment.
The ACER's Trade Reporting User Manual (TRUM) mentions, from the Agency's perspective, the ACER code is the "preference", but all the other above codes may also be used. Let's add - if these other codes were included in the registration information submitted by the market participant to CEREMP.
The specific - but as practice may prove - default scenario may occur in the situation where an organised market place (OMP) is reporting on behalf of the market participant. In this case the ACER code may not be known (note that contracts concluded outside an organised market place represent the only instance where trade data are to be reported by market participants themselves).
If the ACER code has not been provided by the market participant to the organised market place reporting on behalf of the market participant, ACER indicates one of the alternative codes listed above should be used, otherwise the report will be rejected as invalid.
As regards the LEI code, TRUM observes that if a market participant is already using the LEI for EMIR reporting that market participant could use the LEI code also for REMIT reporting.
If market participants prefer the LEI because it is already used for EMIR, they are free to use it as long as the LEI has been provided to the NRAs in the registration process.
If a market participant is using an ACER Registration Code, the market participant/counterparty will be able to verify the identity of the other market participant from the European register of market participants published by the ACER and available at the ACER's website.
It is also useful to note, the ID of the other market participant or counterparty to the transaction needs to be reported only when reporting bilateral trades, including those bilateral trades that take place on broker platforms.
If, in turn, the trade takes place on an energy exchange and the other counterparty is a CCP, clearing house or a clearing member, the relevant field of the reporting form be left blank.
ACER's Questions & Answers on REMIT explain how market participants that play several roles (e.g. a TSO that has also a capacity trading platform) should be identified and whether it is allowed that one organisation has several ACER codes.
The ACER clarification is the ACER code does not distinguish by roles, but aims at uniquely identifying market participants.
A market participant with several roles will therefore still be identified by one unique ACER code.
It is interesting that the ACER envisions situations where reporting for bilateral trades is made with the use of a fictitious ACER Code.
This relates to trades concluded with non-REMIT market participants, REMIT market participant not registered with any NRA yet or a non-EU market players.
Such a designation takes the form of "ACERNONMP.EU" (see box).
If, however, a market participant designated with the trade report with "ACERNONMP.EU" subsequently registers with the competent NRA and informs the counterparty of its ACER code (or any other reportable code) there is a requirement to send a modification report to update the code in previous reports.
ACER Code is populated in field 121 of the REMIT Registration Format.
It is noteworthy, in the Functioning and Usefulness of the European Register of Market Participants, ACER's Public Consultation Paper PC_2016_R_01, 18 March 2016 the need to ensure the traceability of relevant changes in the registration records has been raised.
Consequently, it has been proposed to supplement, in addition to field 121 (ACER code'), two new fields to the REMIT Registration Format:
- one indicating previously used ACER codes; and
The identification of the relationship between ACER codes could be provided by selecting the following types:
- same person previously registered in another Member State;
- incorporation of a registered market participant;
- spin-off from a registered market participant;
Indeed, the implementation of the above improvement could have a merit for the proper identification of wholesale energy market participants.
Another important aspect in the aforementioned ACER Report of 18 March 2016 forms the issue that some counterparties and organised market places (OMPs) voluntarily require market participants to be registered in the European register of market participants before they can trade with them/in their platforms.
The Report rises to the forefront the introduction of this as a legal requirement to benefit the integrity and transparency of the wholesale energy markets and opens the discussion on the pros and cons of introducing this potential new legal obligation.
See also: RRM requirements
|Last Updated on Thursday, 18 May 2017 20:17|