Europex responds to ACER public consultation on “Trade Reporting User Manual (TRUM)” and “Registered Reporting Mechanism (RRM)” Requirements

Brussels, 2 September 2014 | Europex welcomes the opportunity to take part in ACER’s public consultations on both, the Trade Reporting User Manual (TRUM) and “Registered Reporting Mechanism (RRM)” Requirements. According to draft REMIT Implementing Acts (“IA”), reporting obligation for transactions in standard contracts, including orders to trade, will begin six months after the adoption of the IA by the European Commission. In the opinion of Europex, precise and exhaustive guidance on the requirements for reporting entities is indispensable for prompt and efficient launch of the reporting obligation in the wholesale energy market. Therefore, all necessary information, including technical specification mentioned in the draft of TRUM, should be provided as soon as possible. Furthermore, Europex is concerned about the limitation preventing market participants from reporting trade data directly to the Agency that emerges from the TRUM. ACER maintains that the only case in which trade data may be reported by market participants themselves is when a contract is concluded outside an organised market place. Europex would like to emphasise that such restriction is contrary to art. 8 of REMIT which directly allows market participants to report. Therefore, it is crucial to retract such “indirect obligation” of third parties, such as organised market places, to report the data.

Please find both consultation responses attached.