DCO N. 01/2023: MGAS - PROPOSAL TO INTRODUCE THE TRADE CANCELLATION PROCEDURE
Expiration Date: 17/04/2023
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GME Proposal
17-04-2023
With DCO no. 1/2023 GME intends to collect observations from the stakeholders and market participants about the proposal to provide further tools, among others, which natural gas market participants already dispose of, to manage the error when entering bids on the continuous trading market. GME developed this idea in light of the significant increase in traded volumes observed on the market, as well as the increase in volatility, also intra-session, reported, after the current geo-political crisis.
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All interested parties are invited to submit their observations in writing to GME - Governance no later than 5 May 2023, the closing date for this consultation, according to the following method:
Parties who intend to safeguard the confidentiality or secrecy of the documentation sent, in whole or in part, are required to state which parts of their documentation must be considered as confidential.
DCO n. 1/2023
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MASE Approval
22-11-2023
Participants are hereby informed that, with Ministerial Decree 387 of 20-11-2023, the Minister of the Environment and Energy Security, having heard the favourable opinion of the ARERA (Energy, Network and Environment Regulatory Authority) (Opinion 407/2023/I/gas) has approved the ordinary amendments to the Natural Gas Market Regulation (MGAS Regulation), made pursuant to Article 3, paragraph 3.5, of the Regulation, in order to introduce the Trade Cancellation procedure.
Therefore, starting from 28 November 2023 the participants will be able to request the activation of the Trade Cancellation procedure. At the same time, on 28 November 2023, the Technical Implementing Provision n. 21 MGAS will enter into force, with the implementation and procedural rules of the Trade Cancellation procedure, as well as the updated versions of Technical Rules n. 13 MGAS and Technical Rules n. 16 MGAS, adjusted following the changes introduced within the MGAS, here made available in advance, for information purposes only.
It must be noted also that with the same Ministerial Decree 387 of 20-11-2023, the Minister of the Environment and Energy Security, having heard the favourable opinion of the Energy, Network and Environment Regulatory Authority (Opinion 19 July 2022 341/2022/I/com), approved the urgent amendments to the MGAS Regulation and to the Integrated Text of the Electricity Market Rules (ME Regulations), entered into force on 21 March 2022, made in order to introduce transitional methods on the subject of payment regulation.
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Date of pubblication:
22/11/2023
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Completed
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CONSULTATION DOCUMENT NO. 02/2019 NATURAL-GAS MARKET - INTRODUCTION OF THE WEEKEND PRODUCT
Expiration Date: 05/09/2019
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GME Proposal
05-09-2019
With the Consultation Document no. 02/2019 GME intends to gather observations and comments in relation to the proposal to introduce the weekend product in the MGAS, as well as to allow the trading of this new product also in the market making activity.
This proposal is aimed at enriching the offer of the products available for trading in the spot gas markets, in order to provide participants with a flexible operational tool that allows them to anticipate, in the previous working days, the trading referred to gas days falling during the weekend (i.e. Saturday and Sunday).
Interested parties must send their comments in writing to GME - Governance, by and no later than 19 September 2019, the closing date of this consultation in one of the following modalities:
- fax: 06.8012-4524
- post: Gestore dei Mercati Energetici S.p.A.
Viale Maresciallo Pilsudski, 122/124
00197 – Roma
Parties wishing to fully or partly safeguard the confidentiality or secrecy of the documentation sent are required to indicate which parts of their documentation are to be considered confidential.
Consultation Document no. 02/2019
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MISE Approval
16-12-2019
Participants are hereby informed that the following amendments have been approved by Decree of the Ministry of Economic Development (MiSE) dated 12 December 2019 and published on the MiSE website:
- to the Electricity Market Rules (hereinafter: ME Rules) regarding the repeal of the provisions concerning the platform for the physical delivery of financial contracts concluded on IDEX (CDE). This amendment was made as a result of the elimination by Borsa Italiana S.p.A. of the option for physical delivery of electricity on the ME underlying the derivative financial contracts on electricity concluded by participants on the IDEX.
- to the Natural Gas Market Rules (hereinafter: MGAS Rules) concerning:
- the introduction of the "weekend product" on the MGP-GAS;
- the organisation and management, within the MP-GAS, of the new segment for the supply of system gas (AGS) to allow Snam Rete Gas S.p.A. the supply of the resources necessary for the functioning of the gas system according to the criteria and procedures established by ARERA with resolution 451/2019/R/GAS;
- the repeal of any reference to the CDE platform, following the repeal of the provisions regulating the functioning of this platform from the ME Rules;
- formal adjustments aimed at making the provisions of the MGAS Rules in line with the adoption, by Snam Rete Gas S.p.A., of the EIC code (Energy Identification Code) as the code for the identification of participants at the PSV.
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to the Natural Gas Trading Platform Rules (hereinafter: P-GAS Rules) aimed at making the provisions contained therein in line with the adoption, by Snam Rete Gas S.p.A., of the EIC code (Energy Identification Code).
The new versions of the ME Rules, the MGAS Rules and the P-GAS Rules - as well as the related Technical Rules (DTF) and the additional amended documentation - are below provided for information purposes only.
In particular, the ME Rules and the P-GAS Rules will become effective starting from 1 January 2020, while the MGAS Rules will become effective and will be applied for operations referred to the gas-day 1 January 2020.
Therefore, with reference to the MGAS Rules, note should be taken on the following:
ELECTRICITY MARKETS
- Electricity Market Rules - (encl. Annex 3 – Integrated bank guarantee without expiration form)
- Letter amending the non-interest-bearing cash deposit
- Guarantees allocation form (before netting)
- Guarantee allocation form netting
- ME Technical Rules:
o TECHNICAL RULE no. 03 rev. 07 ME
o TECHNICAL RULE no. 04 rev. 08 ME
o TECHNICAL RULE no. 05 rev. 07 ME
o TECHNICAL RULE no. 07 rev. 09 ME
o TECHNICAL RULE no. 08 rev. 14 ME
o TECHNICAL RULE no. 01 Rev. 02 CDE (repealed)
NATURAL GAS MARKET
- Natural Gas Market Rules - (encl. Annex A – Market Participation Application from; Annex C – Integrated bank guarantee without expiration form)
- Letter amending the non-interest-bearing cash deposit
- MGAS Guarantee allocation form
- MGAS Technical Rules:
o TECHNICAL RULE no. 04 rev. 05 MGAS
o TECHNICAL RULE no. 06 rev. 04 MGAS
o TECHNICAL RULE no. 07 rev. 03 MGAS
o TECHNICAL RULE no. 10 rev. 01 MGAS
o TECHNICAL RULE no. 15 rev. 02 MGAS
o TECHNICAL RULE no. 19 rev. 01 MGAS
o TECHNICAL RULE no. 20 MGAS
P-GAS PLATFORM
- P-GAS Rules (encl. Annex 1 – P-GAS Participation Application; Annex 2 – P-GAS Participation Agreement)
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Date of pubblication:
05/09/2019
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Completed
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DCO 02/17 PROPOSAL TO MODIFY THE EXPRESSION OF THE MINIMUM GAS VOLUME UNDER THE CONTRACTS TRADED ON THE NATURAL-GAS MARKET
Expiration Date: 28/11/2017
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GME Proposal
07-11-2017
By decree of 13 March 2017, the Minister of Economic Development approved amendments to the "Natural-Gas Market Rules", which included, inter alia, regulatory provisions for the implementation of measures aimed at improving the liquidity of natural-gas markets, as previously described by GME in the Consultation Paper n. 06/2016.
In implementing these regulatory measures, GME has published a subsequent Consultation Paper n. 01/2017 detailing the terms and conditions for carrying out the market making activity.
In order to make market-making activity effective in promoting market liquidity, with the activation of the market making service, and also to facilitate the comparability of the prices by market participants, it is necessary to standardize the contract size of the market products currently traded on MGAS with the one adopted in the major European markets. This alignment plays a crucial role in the bidding strategies of market participants, and in particular, of those who will be available to carry out the market making activity, with the possibility of a faster and easier comparison of bids/offers for the products traded on different markets.
In order to illustrate the implications connected to the proposal for amendments to the contract size, GME defines in this Consultation Paper the details of the amendment itself, with a prompt indication of the products traded on the MGAS that would be involved in the said amendment.
All interested parties may provide their comments about the content of this document.
Such comments shall be provided, in writing, to GME - Governance, by and no later than 21st November 2017, time limit of this consultation, by one of the following methods:
- e-mail: info@mercatoelettrico.org
- fax: 06.8012-4524
- mail: Gestore dei mercati energetici S.p.A.
Viale Maresciallo Pilsudski, 122 - 124
Parties wishing to safeguard the confidentiality or secrecy of all or part of the documentation sent shall indicate which parts of their documentation are to be considered confidential.
DCO 02/17
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MISE Approval
21-12-2017
GME informs that, by Ministerial Decree 18-12-2017, the Minister for Economic Development, having heard the favorable opinion of the Italian Regulatory Authority of Electricity, Gas and Water (Opinion 30 November 2017 no 804/2017/I/GAS), approved:
· the urgent amendments to the MGAS Rules made pursuant to Article 3, paragraph 3.6 of the same Rules and effective from 1 October, in order to overcome the transitional management procedures of the MGS referred to in point 6 of AEEGSI Resolution no. 66/2017/R/GAS, as well as to adapt the same Rules as required by subsequent AEEGSI Resolution no. 349/2017/R/GAS on the "neutrality" of the Balancing Operator;
· the ordinary amendments to the MGAS Rules made pursuant to Article 3, paragraph 3.5, of the same Rules – previously described by GME in the Consultation Paper n. 02/2017 - in order to standardize the "contract size" of the products currently traded on MGP-GAS, MI-GAS, MPL and MT-GAS with the one adopted on the main European gas markets.
The aforementioned Decree also specified that the ordinary amendments to the MGAS Rules above will be effective starting from the date notified by GME and in any case no later than January 31, 2018. This date will be communicated by means of a specific notice on GME's website, which will be published with at least 15 days’ notice.
For mere explanatory purposes, the MGAS Rules is available at the end of this notice, also including the ordinary above-mentioned amendments.
MGAS Rules
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Date of pubblication:
07/11/2017
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Completed
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DCO N. 01/2017 MARKET MAKING IN THE MGAS
Expiration Date: 15/09/2017
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GME Proposal
31-05-2017
By decree of March 13, 2017 of the Minister for Economic Development, the amendments to the "Natural Gas Market Discipline" were approved, aiming at the transition to a new balancing regime and, inter alia, the introduction of the market making activity, aimed at improving the liquidity of natural gas markets.
IIn particular, Article 27 of the MGAS Rules provides that, in order to improve the liquidity of products traded on the market, GME may provide for Market Making activity in the MGAS, in accordance with the terms and conditions defined in the Technical Rules. (...) participants interested in carrying out the Market Making shall submit GME a request, in accordance with the terms and conditions set forth in the Technical Rules.
In order to fully implement this provision, GME wishes, with this consultation, to provide operators with a description of the regulatory and operational framework to define the arrangements for carrying out the market making activity in the gas market.
Any interested person/entity must submit, in writing, its comments to GME - Institutional Relations and Communication, no later than 20 June 2017, end date of this consultation by one of the following means:
- e-mail: info@mercatoelettrico.org
- fax: 06.8012-4524
- mail: Gestore dei mercati energetici S.p.A. Viale Maresciallo Pilsudski, 122 - 124 00197 – Roma
Participants are requested to submit their comments to GME also indicating whether they are interested in carrying out market-making activities or if they are just interested in the use of such an activity. In the document, GME has also included consultation suggestions, where it considers it useful to receive considerations specific to the proposal for market making activity from participants.
Those wishing to safeguard the confidentiality or secrecy, in whole or in part, of the documentation submitted are required to indicate which parts of their documents shall be treated as confidential.
DCO 01/2017
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MISE Approval
21-12-2017
GME informs that, by Ministerial Decree 18-12-2017, the Minister for Economic Development, having heard the favorable opinion of the Italian Regulatory Authority of Electricity, Gas and Water (Opinion 30 November 2017 no 804/2017/I/GAS), approved:
· the urgent amendments to the MGAS Rules made pursuant to Article 3, paragraph 3.6 of the same Rules and effective from 1 October, in order to overcome the transitional management procedures of the MGS referred to in point 6 of AEEGSI Resolution no. 66/2017/R/GAS, as well as to adapt the same Rules as required by subsequent AEEGSI Resolution no. 349/2017/R/GAS on the "neutrality" of the Balancing Operator;
· the ordinary amendments to the MGAS Rules made pursuant to Article 3, paragraph 3.5, of the same Rules – previously described by GME in the Consultation Paper n. 02/2017 - in order to standardize the "contract size" of the products currently traded on MGP-GAS, MI-GAS, MPL and MT-GAS with the one adopted on the main European gas markets.
The aforementioned Decree also specified that the ordinary amendments to the MGAS Rules above will be effective starting from the date notified by GME and in any case no later than January 31, 2018. This date will be communicated by means of a specific notice on GME's website, which will be published with at least 15 days’ notice.
For mere explanatory purposes, the MGAS Rules is available at the end of this notice, also including the ordinary above-mentioned amendments.
MGAS Rules
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Date of pubblication:
31/05/2017
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Completed
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NATURAL GAS BALANCING PURSUANT TO FORMER AEEGSI’S RESOLUTION 312/2016/R/GAS: IMPLEMENTATION OF THE REGIME PHASE
Expiration Date: 23/06/2017
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GME Proposal
02-12-2016
Due to the transition to the “regime phase” of the new structure of the balancing of the natural gas system provided for in the AEEGSI’s Decision n. 312/2016/R/teca/Documenti/20161201_DC GAS of 16 June 2016, aiming to achieve "Bilanciamento gas, in attuazione del Regolamento (UE) 312/2014”, Gestore dei mercati energetici (hereinafter: GME) publishes this consultation document, under Article 3, paragraph 3.5, of the MGAS Rules, which describes to the Market Participants the new gas market (MGAS) structure that will result from this transition, in order to collect comments from any stakeholders. In particular, the transition to the “regime phase” will imply the transition both of the trading of locational products (MPL) and of the trading relating to the adjustment of the volumes handled from the storage (MGS) to the MGAS and the consequent operational closure of the PB-GAS.
Without prejudice to the main objective of this consultation document, this opportunity allows GME submitting to the assessment of the stakeholders also proposals to amend other aspects concerning the operation of the MGAS, which are not strictly related to the “regime phase” of the balancing and which may consequently be introduced even after the launch of such a regime phase. Those proposals may be subject to revision in the light of what has been observed on the market, as well as the changing environment arisen following the start of the new balancing regime.
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The parties must submit, in writing, their comments to GME - Institutional Relations and Communication, no later than December 22, 2016, end date of this consultation by one of the following ways:
- e-mail: info@mercatoelettrico.org
- fax: +39 06.8012-4524
- mail: Gestore dei mercati energetici S.p.A.
Viale Maresciallo Pilsudski, 122 - 124
00197 – Rome - Italy
Those wishing to safeguard the confidentiality or secrecy, in whole or in part, of the documentation submitted are required to indicate which parts of their documents shall be treated as confidential.
Download DCO 6/2016
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MISE Approval
15-03-2017
The Ministry of Economic Development, with Ministerial decree 13-03-2017 and after hearing the favourable opinion of the Italian Regulatory Authority for Electricity, Gas and Water ( Opinion 98/2017/I/GAS of March 3, 2017), approved the amendments to the Natural-Gas Market Rules (MGAS Rules) elaborated by Gestore dei mercati energetici S.p.A. (GME) in compliance with Article 3, paragraph 3.5 of the abovementioned Rules, with the purpose of implementing the “regime” phase of the new gas balancing system under Resolution No. 312/2016/R/GAS.
The aforesaid amendments shall enter into force on April 1, 20171, as pursuant to the mentioned Decree.
With the present notice, GME communicates that the new version of the MGAS Rules is available, together with the related updated Technical Rules (DTF MGAS), for information purposes only. With regard to this, please note that, given the amendments applied to the MGAS Rules for the implementation of the abovesaid “regime phase” – which, as is well known, led to a different Gas Market setting – and following the update of the Technical Rules, a new Rule numbering has been applied.
Please use the link below to find out the new MGAS Rules together with the updated and renumbered Technical Rules – DTF MGAS:
MGAS Rules
Technical rule no 1: "Notifications about the procedure of admission to/exclusion from themarket"
Technical rule no 2: "Holidays"
Technical rule no 3: "Unit of measurement"
Technical rule no 4: "Access to the Information System"
Technical rule no 5: "Timing of the activities of the MPL and MGS sessions"
Technical rule no 6: "Submission of Offers/Bids"
Technical rule no 7: "Types of contracts, Duration of the Trading Period and Cascading Mechanism"
Technical rule no 8: "Data and Information concerning the Participation in the MGAS, validation of offers and maximum exposure to Snam Rete Gas"
Technical rule no 9: "Gas Storage Providers on the MGS"
Technical rule no 10: "Registration of the MGAS net position and MPL position to the PSV"
Technical rule no 11: "Reference price and closing price"
Technical rule no 12: "Closing of open positions"
Technical rule no 13: "Emergency Communications between GME and Market Participants"
Technical rule no 14: "Loss of Qualifications or Default by the Bank Issuing the Bank Guarantee"
Technical rule no 15: "Bids/Asks Adequacy Verification of Guarantee Coverage"
Technical rule no 16: "Invoicing of payables/receivables and settlement of payments"
Technical rule no 17: "VAT Taxation in the Gas Market"
1For further details on the implementation of the “regime” phase of the new gas balancing system as well as on the conditions for the participation in the new MGAS, please refer to the press release of March 7, 2017
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Date of pubblication:
15/03/2016
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Completed
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PROPOSED AMENDMENT OF THE TIMING OF BILLING AND PAYMENT ON THE GAS MARKET - 2
Expiration Date: 11/04/2016
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GME Proposal
19-11-2015
Following the previous DCO no. 01/2015, showing a first proposal to amend the rules of settlement on the gas market (MGAS), by this consultation, GME intends to submit to the Market Participants an updated version of the above proposal drawn up in order to harmonize the billing and payment cycle of the MGAS with the timing and the manner prescribed for the Electricity Market (ME) and the PCE - shown within the DCO no. 07/2014 - while also taking into account the comments made by the Market Participants in response to that consulting procedure on the matter.
In addition, it should be noted that the implementation of the proposal, which includes a series of settlements on a weekly basis as part of the MGAS, would result in a significant benefit to Market Participants in terms of lower total charges related to participation in the market, reducing exposure each of them to GME in terms of guarantees, also in light of the startup of the new balancing mechanism under European Rules 312/2014.
For completeness, it should be noted that the comments contained in this document refer to the guarantee scheme currently in force, but remain valid, mutatis mutandis, even in the presence of the future integrated system of guarantees referred to in DCO 05/2014.
Stakeholders are invited to submit their remarks with reference to the operating methods described in the document.
Such comments must be received, in writing, bye GSE - Institutional Relations and Communication, no later than friday 11 December 2015, end date of this consultation, by one of the following ways:
e-mail: info@mercatoelettrico.org
fax: +39 06.8012-4524
mail: Gestore dei mercati energetici S.p.A.
Viale Maresciallo Pilsudski, 122-124
00197 – Rome
Those wishing to safeguard the confidentiality or secrecy, in whole or in part, of documents sent are required to specify which parts of their documents shall be treated as confidential.
Download DCO 04/2015
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Date of pubblication:
19/11/2015
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Completed
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PROPOSAL TO CHANGE BILLING AND PAYMENT TIMING ON THE GAS MARKET
Expiration Date: 22/03/2016
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GME proposal
28-04-2015
In the implementation of the provisions set out in article 30 of law 99/09 and article 32 of Leg. Decree 93/11, GME (Manager of Energy Markets) has been entrusted with the organisation and management of the wholesale market for natural gas (MGAS) whose current configuration includes the spot market for natural gas (MP-GAS) – which, in turn, is structured in day-ahead and intraday markets – and the futures market (MT-GAS) in which, from 2 September 2013, annual (calendar and thermal), half-yearly, quarterly, monthly and BoM (balance of month) products are negotiable by continuous trading.
Within the improvements aimed at making the market more efficient and economic as a whole, GME, in carrying out its role as market operator and continuing the solution envisaged for the electricity market with regard to DCO no. 07/2014, proposes a change in the current monthly settlement rules. In particular, the proposal set out below which, through the introduction of a weekly billing and payment timing for the natural gas market as well, would mean a step forward in the process of harmonizing legislation between different Regulations/Frameworks at least for those areas whose provisions can be applied more widely across the different markets of GME.
The implementation of a reduced settlement cycle with respect to current timings would also mean a significant benefit to the participants in terms of lower overall charges arising from participation in the market by reducing individual exposure towards GME in terms of guarantees.
For the sake of clarity, it should be pointed out that the points made in this document refer to the currently applicable guarantee system, but, with appropriate adjustments, they will still apply to a future integrated guarantee system referred to in DCO 05/2014 as well.
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Interested parties are invited to comment on the operational methods described in this document in addition to the insights from S.1. to S.2. in particular, which are available for consultation.
Any comments should be sent in writing to GME - Institutional Relations & Communications (“Relazioni Istituzionali e Comunicazione”) - by 25 May 2015 at the latest, closing date for this consultation, in one of the following ways:
e-mail: info@mercatoelettrico.org
fax: 06.8012-4524
post: Gestore dei mercati energetici S.p.A.
Viale Maresciallo Pilsudski, 122-124
00197 - Roma
Anyone wanting to maintain secrecy and confidentiality, for whole or part, of the documentation sent, must specify which parts of the documentation are to be considered confidential.
Download DCO 01/2015
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Date of pubblication:
28/04/2015
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Completed
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M-GAS DISCIPLINARY MEASURES
Expiration Date: 06/07/2015
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GME proposal
24-11-2014
With this consultation document (Consultation Document 8/2014), GME intends to gather comments and suggestions from interested parties about some changes to the provisions of the Rules and Regulations governing its markets and platforms. The proposed changes are focused on: the disciplinary measures that GME adopts in case of breaches of the Rules and Regulations by participants; the requirements for participation in/suspension/exclusion from the market/s; and the provisions regarding the resolution of complaints about market operations.
Considering that the above provisions have a cross-cutting nature within the different markets/platforms that GME organises and manages, apart from obvious differences related to the specificity of each market, GME plans to globally revise the Rules/Regulations, with a view to achieving a structured and homogeneous regulatory setting to the benefit, among others, of participants active on the different markets/platforms.
Interested parties are invited to send their comments in writing to GME’s Institutional Relations & Communication - “ Relazioni Istituzionali e Comunicazione”- by 11 December at the latest (end date of the consultation) in one of the following ways:
· by e-mail to: info@mercatoelettrico.org
· by fax to: +39-06-8012 4524
· by mail to: Gestore dei mercati energetici S.p.A.
Largo Giuseppe Tartini, 3/4
00198 – Roma
If you want us to keep all or part of your comments confidential, please specify which parts of your document are to be kept confidential.
Download Consultation Document 8/2014
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Date of pubblication:
24/11/2014
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Completed
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RULES FOR THE NATURAL GAS MARKET
Expiration Date: 11/04/2016
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GME Proposal
19-10-2012
On 1 June 2011, Legislative Decree no. 93 was approved. The Decree (published in “Gazzetta Ufficiale” no. 148 of 28 June 2011 - “Supplemento Ordinario” - hereafter Legislative Decree 93/11) implemented Directives 2009/72/EC, 2009/73/EC and 2008/92/EC concerning common rules for the internal market in electricity, in natural gas and a Community procedure to improve the transparency of gas and electricity prices charged to industrial end users, repealing Directives 2003/54/EC and 2003/55/EC. In particular, with a view to favouring the liquidity of the gas market, article 32, para. 2 of the Decree establishes that: within six months of the date of enforcement of this Decree, “Gestore dei Mercati Energetici” (referred to in article 5 of Legislative Decree no. 79 of 16 March 1999 - GME) shall take over the management of physical forward markets of natural gas. To this end, “Autorità per l’Energia Elettrica e il Gas” (electricity & gas regulator – AEEG) shall lay down regulatory provisions enabling GME to carry out such activities and to act as a central counterparty to the trades in the above markets, as a user at the “Punto di Scambio Virtuale” (Virtual Trading Point – PSV) holding an account thereon and as a user of the natural-gas balancing market.
By agreement with the relevant institutions, GME has prepared this consultation document concerning a forward market design proposal, with a view to gathering comments and inputs on the related organisational and operational procedures.
Interested parties should send in their comments in writing to the “ Unità Legale e Regolazione” (Legal & Regulatory Office) of GME within 12 November 2012 at the latest (end date of the consultation)
or
- by fax to +39-06-8012-4524
or
- by mail to Gestore dei mercati energetici S.p.A. Largo Giuseppe Tartini, 3/4 00198 – Roma
If you want us to keep all or part of your comments confidential, please specify which parts of your comments are to be kept confidential.
Go to the Consultation Document
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Date of pubblication:
19/10/2012
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Completed
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