Europex welcomes the opportunity to participate in this consultation and provide detailed input to the ACER proposal. Please note that we respond only to the selected questions listed in the attached document.
Europex explicitly welcomes and fully supports the Commission’s legislative proposal to extend the derogation in Article 199a of the VAT Directive allowing Member States to apply the domestic reverse charge mechanism (DRCM) to transactions in electricity, gas, emission allowances and Guarantees of Origin (GOs).
Europex is fully aligned with the core objectives of the Principles to ensure that commodity derivatives markets can serve their fundamental role of facilitating fair and efficient price discovery and hedging in a transparent, secure and well-regulated trading environment, while remaining free from market manipulation and other abusive practices.
We welcome this opportunity to provide input to the ENTSO-E and EU DSO proposal for a Network Code on Cybersecurity aspects of cross-border electricity flows.
We believe it is crucial that the illiquid market and Large-In-Scale (LIS) transactions waiver methodologies will consider the unique characteristics of commodity trading, one of them being the important role of pre-arranged trading for the development of on-screen trading.
We support ACER’s approach to delete Article 59(5) of the proposal, which proposes a cap on remuneration of LTTRs in case of fallback allocation. We do not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.
Europex fully supports the EU target design for balancing energy markets, including the implementation of cross-border marginal pricing. However, during the transition to the European balancing platforms, we acknowledge the potential risks of ‘exaggeratedly high’ balancing prices, as described by the TSOs.
Bidding zones are a fundamental part of the electricity market design in Europe. Adequate attention must be paid to the development of alternative bidding zone configurations as well as their assessment.
To ensure that the policy objectives set out in the Green Deal get delivered at least cost and that the EU’s internal market principles are upheld, State Aid rules need to find the right balance between supporting decarbonisation projects and minimising distortion of competition and trade in the Internal Energy Market.
We welcome the opportunity to provide feedback to ESMA’s draft proposals for the review of RTS 21 and ITS 4 as well as the proposal for new technical standards for position management controls. Europex’ members have gained extensive experience with the implementation of the MiFID II position limit regime and position management provisions.
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