Brussels, 2 November 2012 |It its position paper, Europex would like to point out the following concern: in the latest stakeholder consultation on the Implementation of a Data and Transaction Reporting Framework for Wholesale Energy Markets, the European Commission is under the impression that organised market places can be considered as market participants under REMIT. Given that Energy Exchanges fall under the purview of organised market places, they can never be considered as market participants. This would clearly create a conflict of interest between their role and responsibility as entities that bring together market participants’ buying and selling interests. It is therefore of utmost importance that Energy Exchanges are considered to be organised market places under REMIT only and NOT as market participants.
As the notion of being a market participant would have considerable and unintended consequences for the status of Energy Exchanges, this position paper shall provide arguments as to why this interpretation is erroneous and not in line with neither REMIT nor the 2nd edition of the ACER REMIT Guidelines.
Please find the position paper attached.