ACER REMIT: Transaction Reporting Logic Changes – Part 4

Welcome back to our ‘ACER REMIT Reporting’ series, where we illuminate the recent changes introduced by ACER for REMIT Reporting in the European Union. In part one, we provided an introduction to the changes REMIT had recently enacted, and how they may affect your business. In part two, we went on to highlight some of the important dates and deadlines to keep in mind to stay compliant. We also illustrated a timeline of events vital to understanding what the changes are, and why they were introduced. Then, part three, illustrates a side-by-side comparison of the most important changes against Essentia’s recommended actions. Now, to conclude our series, in this part four, you will see a recap of the key items we want you to remember and a step-by-step plan that you can use to ensure you have addressed the correct areas of implementation to support Day-1 compliance.

What Do We Know So Far?

ACER’s emphasis on trade data quality has never been higher, hence the incoming rule changes are significant. The amendments provided in TRUM Version 5.2 focus on clarifying the reporting obligations for broker OMPs and also for market participants entering into transactions on wholesale energy markets via third party accounts.  It makes no difference whether your firm  resides within the EU or whether you are professional investors. The REMIT rules apply evenly to anyone who participates in , or whose conduct affects, wholesale energy markets within the European Union.

Organized market places (OMPs) will be obliged under the new rules to provide full order book data set to ACER. Keep in mind that OMPs will also be updating the REMIT XML files to comply with ACER’s REMIT Table 1_V3 reporting schema. This essentially phases out Table1_V1 and Table1_V2 schemas in June and October 2023 respectively.   Market participants who take advantage of their OMPs REMIT reporting services are reminded of their obligation to check the reports provided by their OMPs.

Market participants will be required to provide transaction and/or fundamental data through registered reporting mechanisms (“RRMs”).  Market Participants who have not opted for any REMIT reporting services via an RRM (Registered Reporting Mechanism), are advised to prepare for this change and ensure they conform to the new standards and messaging formats.  

A new version (electronic format Version 3) for the reporting of REMIT transactions will be required for the reporting of Table 1 transactions. Changes cover revised field attributes and data values for transaction data, fundamental data requirements and inside reporting,  and lastly mandatory alignment of the electronic format with the TRUM.

What Should You Do Next?

Essentia is helping market participants and vendors adopt to these ACER Remit trade reporting revisions. Developed from our unsurpassed industry experience, and proven success in regulatory compliance, Essentia has specially curated the following 3-step model to help our clients prepare and meet the demands of the revised reporting requirements:

  1. Orient & Assess – complete a regulatory change impact assessment to identify areas requiring mandatory upgrades.
  2. Simplify & Solve – reduce process inefficiencies & curate a remediation plan that includes reasonable design, solution requirements and customization of your CTRM to support the new mandates.
  3. Design & Deliver – build or update your infrastructure that initiates the message within your CTRM using the latest required messaging formats, automates submission of the reported transaction to an RRM or TR, support an error management process, and facilitate ‘Verification’ of your reported trades by reconciling it against your internal books to ensure that your trading records match what has been received by the Regulator (e.g., ACER).  

Where Do I Start?

Now that you know what the changes are and best practices for implementation, take a look at the chart below to better understand how we implement this approach:

Essentia has tools designed and built to deliver post-reporting functionality, performing report completeness and accuracy checks on what an SDR has stored against your internal books & systems.  We also provide tools that provide data analytics to help enterprises better address error management, timely reporting, and reporting accuracy.   

Closing the Reporting Loop

The latest round of rule revisions is designed to increase enforcement and trade data element standardization across jurisdictions.  The market will be required to adopt these revisions regardless of what asset class they trade financials in, or what jurisdiction(s) they trade under or face financial penalties.  There is an awful lot of work ahead for everyone involved.  

Essentia is here to engage with your business to help you understand what the impacts are to both the business and operating models of your firm, regardless of the regulatory regime (CFTC, SEC, EMIR, CSA, MAS, MIFIR, FCA).   

These regulatory updates will be provided regularly going forward.  Stay tuned for our next series covering the critical derivatives reporting changes the CFTC has introduced under the ‘CFTC Phase 2’ initiative, impacting both Swap Dealers and End-Users. Also, make sure to catch up on part-1, part-2, and part-3 of our ACER Reporting series in case you missed them.


Rahim Kabani, Director, Essentia Advisory Partners

Rahim Kabani is a Director at Essentia Advisory Partners where he heads our Regulatory Compliance Advisory service. He has over 15 years of derivatives trading & regulatory compliance experience spanning multiple jurisdictions. Email: rahim_kabani@epam.com

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