Brussels, 5 May 2014 | Europex welcomes the opportunity to take part in the consultation on the proposed Trade Reporting User Manual (TRUM). As many issues have already been consulted upon, the present response explicitly refers to the Europex response to Public consultation on technical requirements for data reporting under REMIT & ACER Guidelines for the registration of Registered Reporting Mechanisms and for the registration of Regulated Information Services. The current draft REMIT Implementing Acts stipulate that reporting obligation for transactions in standardised contracts, including orders to trade, will begin six months after the adoption of the IA by the European Commission. Precise clarification of the requirements for the reporting entities is indispensable for an undisturbed launch of the reporting obligation in the wholesale energy market. Europex would like to strongly emphasise that the proposed timeframe of six months for the implementation of reporting channels is not adequate given the scope and complexity of this project, which encompasses sensitive business data. Any technical or security failure in reporting communication could negatively affect the whole energy market. The necessary technical information required to build reporting channels (e.g. data integrity, signing and encrypting of data and authentication of parties) has not been explained so far. Europex would expect the TRUM to be a source of detailed information on these issues.
It should be emphasised that REMIT does not require energy exchanges to report the trading data on behalf of their members. The legal obligation to provide the data to ACER lies with market participants. However, for the case that exchanges are willing – in the light of the possibility foreseen in art. 8(4) of REMIT – to provide the service of reporting transactions and orders to trade on behalf of their participants, it is necessary to ensure a common understanding of the details regarding information to be reported.
Please find the consultation response attached.