REMIT RRM Switching
The transaction reporting requirements of the Regulations on Energy Market Integrity and Transparency (REMIT) requires that market participants (MPs) submit their reportable bilateral trades to an ACER approved registered reporting mechanism (RRM).
The RRM acts as an intermediary between the many market participants and the regulators reporting database (ARIS). The RRM is responsible for validating the data provided by the participants, based on a set of standardised rules provide by ACER, and then ensuring that such data is transmitted onto the ARIS system in the approved XML format.
One of the biggest issues faced by REMIT participants is the disconnection between their trading activity across multiple venues – typically with each trading exchange or broker electing to report data to their own RRM service – leading to data being scattered across multiple providers making reconciliation an unwieldy exercise.
There are a range of different data types within REMIT, with RRMs being able to elect which types they support;
- Standard Trades (Table 1)
- Non Standard Trades (Table 2)
- Gas Transportation Contracts (Table 3)
- Power Transportation Contracts (Table 4)
- Fundamental Data
At the time of writing, there are 107 approved RRMs, of which only 25 are listed as providing RRM services to any market participant;
- Abide Financial Limited
- BORZEN, organizator trga z električno energijo, d.o.o.
- CEEGEX Ltd.
- CGI IT Czech Republic s.r.o.
- CME Trade Repository Limited
- EFETnet B.V.
- Empower IM Oy
- Energy & More Management GmbH
- European Energy Exchange AG
- EXAA Abwicklungsstelle für Energieprodukte AG
- FGSZ Földgázszállító Zártkörűen Működő Részvénytársaság
- HUPX Ltd.
- ICE Trade Vault Europe Limited
- Kaasupörssi Oy
- LAGIE S.A.
- Nord Pool Spot AS
- Polish Power Exchange
- REGIS-TR, S.A.
- RWE Group Business Services GmbH
- SEEBURGER AG
- Solien, s.r.o.
- UAB GET Baltic
- vp Energieportfolio
Each of these repository services differ slightly in their approach to capturing and validating your trade input data – meaning that more than just being a mechanism for reporting trade data, your choice of RRM can have a large impact on your operational processes and regulatory controls.
Each RRM will have a slightly different model for levying charges – some preferring a per transaction basis, some based on notional volume and others based on an annual membership charge.
Switching, when managed correctly, is likely to result in significant cost savings and potentially much improved technical and operational processes. The key to recognising these gains is to manage the switching process as a discrete piece of work, utilising experience to avoid many common pitfalls.
How We Can Help
One of the operational support services we offer at Belbridge Consulting is the managed switching process from one REMIT RRM to another. This will include the initial cost/benefit analysis and the detailed portfolio analysis tasks – to ensure that you have 100% product coverage when switching.
In order to complete the switch-over, we will provide a full reconciliation of the trades to be closed from the source RRM, against the trades to be opened with the target RRM. This can often prove more complex than it should be, given ACERs validation rules and the need to show that a trade reported under the new RRM is linked to the trade initially reported under the previous RRM.
We’ll also look at the changes to your operational processes and ensure you have sufficient risk controls in place to ensure your transition is as simple as possible – allowing you to recognise the cost savings and operational benefits, without any unexpected operational burdens.