Market participants are required to report to the EU Agency for the Cooperation of Energy Regulators (ACER) through a registered reporting mechanism (RRM). For true market participants (i.e. those that actively trade at an OMP) this has been assisted by the REMIT Implementing Act requiring such trading venues where orders were placed and trades executed in wholesale energy products to offer a data reporting agreement to market participants in respect of those orders and trades. Although the obligation to report remains with market participants, in practice the trading venues will report the details of orders and contracts to an RRM on behalf of market participants.
As most UK renewable generators do no participate more widely in trading venues, they may not have an existing relationship with an OMP for the purposes of reporting. A question to be considered will therefore be the simplest means to access a RRM. Market participants can contract directly with a RRM that offers reporting of non-standard contracts, such as Trayport and EFETnet, or delegate reporting to a third party.
In the first instance however, generators should consider contacting their offtaker (if they have not done so already). As the reporting obligation will apply independently to the buyer under a PPA, they may have already determined their approach to reporting (include by which RRM and in what form). It may be possible to request the offtaker to report on their behalf via its selected RRM. Any delegation of responsibility for reporting will need to be documented in a legal agreement to ensure the responsibilities of both parties are clearly set out. Where a market participant delegates reporting to a third party the market participant will not be held responsible for failures in the completeness, accuracy or timely submission of the data which are the fault of the third party.
Even where an offtaker is not in a position to offer this service, we suggest talking to them in any event.3
As a PPA does not fit easily in the reporting formats developed for standard short term trading products, there is value in discussing common approaches to completing the relevant forms. That said, the core of the information flows regarding PPAs will be volume and price on an on-going basis. We expect most intermittent PPAs with pricing based on a discount to a market index will need to be reported initially as if it is a framework agreement for trades where the volume and price is not known. There will then need to be monthly reporting of each ‘execution’, being the point where the price and volume is known (which is expected to be drawn from monthly invoice data)4