DATA REPORTING PLATFORM (PDR)
Frequently Asked Questions (FAQ)

The other sections of the document make use of the following definitions:

• CEREMP: Centralized European Register of Energy Market Participant, established pursuant to article 9.3 of the REMIT Regulation.

• Operations: orders and transactions related to wholesale energy products

• IAs (Implementing Acts): Implementing Regulation (EU) No. 1348/2014 of the Commission dated December 17, 2014 concerning the reporting of data under Article 8 paragraphs 2 and 6 of the Regulation (EU) No. 1227/2011.

• REMIT: Regulation (EU) No. 1227/2011 of the European Parliament and of the Council dated October 25, 2011 on the integrity and transparency of wholesale energy market

• RRM: Registered Reporting Mechanism

• TRUM: "Transaction Reporting User Manual" document as published by ACER on its REMIT Portal (https://www.acer-remit.eu/)

1.  WHAT IS THE DATA REPORTING?
Data Reporting shall mean the collection of those data needed to monitor the wholesale electricity and natural gas markets carried by ACER pursuant to Art. 8 of REMIT. Such data must be provided, directly or through third parties, by the Market Participants to ACER as described in the Implementing Acts (IAs). The subjects (Market Participants or third parties) who intend to make the transmission of data need to register as an RRMS at ACER.
 
2.  WHAT ARE THE DATA TO BE REPORTED TO ACER?
They must be submitted to ACER:

• Orders and transactions related to standardized contracts for the supply of electricity or natural gas with delivery inside the European Union, as defined in Article 2 of IAs as contracts whose underlying item is a wholesale energy product admitted to trading on a regulated market, regardless of whether or not the transactions are carried out on this market;

• Orders and transactions related to non-standardized contracts for the supply of electricity or natural gas with delivery inside the European Union, as defined in Article 2 of IAs as contracts whose underlying item is a wholesale energy product that does not fall in the category of standardized contract.

• Contracts pertaining to the ability to transport of electricity or natural gas in the European Union, allocated through primary allocation by the TSO, or on the secondary markets.

3. FROM WHEN SHALL SUCH CONTRACTS BE SUBMITTED TO ACER?
The obligation of transmission of the standardized contracts and concluded on one of the organized markets in the list published by ACER on its REMIT portal, is effective from October 7, 2015. The obligation of transmission of standard contracts concluded outside the regulated markets, of those non-standard and the contracts relating to the transportation capacity, is effective from April 7, 2016.

4. HOW DOES GME INTEND TO FULFILL THE DUTY TO MAKE AVAILABLE THE DATA REPORTING SERVICE TO ITS OPERATORS?
According to Article 6 of the IAs, GME - as manager of an organized market - is obliged to offer its Market Participants that request it, a proposal for a service for the transmission to ACER of those data related to those transactions that they carried out on the markets organized by GME. To implement this requirement, GME has identified for its Participants a more direct and complete data reporting service to ACER, developing a special Data Reporting Platform (PDR), through which it’s possible to manage the necessary information flows to/from the Market Participants and ACER. In order to carry out the reporting on behalf of its Market Participants that request it, GME has begun the process of registering with ACER to get the qualification of RRM.
GME may carry out the reporting on behalf of its Market Participants that request it, as it obtained the RRM qualification at ACER on 20/08/2015.

5.  WHAT IS THE PDR AND WHAT IS IT USED FOR?
The PDR (Data Reporting Platform) is an online platform designed by GME to allow the Participants of the wholesale energy market to meet the requirement of transmission to ACER, referred to in Article 8 of REMIT, of the data regarding the transactions they have concluded with reference to the wholesale energy products, in the markets organized and managed by GME and on other platforms on the market, as well as bilaterally. Upon completion, with reference to the contracts concluded bilaterally, GME offers the possibility to Participants registered in the PDR to report ACER also the data on behalf of their contractual counterparties.

6. WHO ARE THE RECIPIENTS OF THE DATA REPORTING SERVICE OFFERED BY GME?
Access to the PDR is allowed only to market participants enrolled in one or more of the energy markets or gas markets of GME, namely: the Electricity Market (ME), the Natural Gas Market (M-GAS), the platform of natural gas balancing, and the P-GAS platform. Therefore, the data reporting service currently excludes those participants registered exclusively to the OTC Registration Platform , to the Platform for the Allocation of Regasification Capacity (PAR), and those participants registered exclusively to environmental markets (MTEE and MGO).^[1]

7. WHICH ARE THE FUNCTIONS OF THE PDR?
GME, through the PDR, offers the Applicant Participants the following services:
· the transmission to ACER, by GME, of the data and information on all transactions concluded on the markets of GME, converted into ACER format;
·  the loading on the platform in ACER format by the Participants, and the subsequent transmission to ACER by GME, of the data and information relating to the transactions concluded outside the markets managed by GME;
· the provision of documentation provided by ACER confirming the success of the data reporting made by GME to ACER;
· the provision already in ACER format of those data concerning transactions they have concluded on the markets managed by GME.

8.  HOW CAN ONE REGISTER TO THE PDR?
The access to the PDR is extended only to those entities that have already acquired the status of Market Participants within the electricity and/or natural-gas markets/platforms managed by GME. To register to the PDR, it is necessary to sign the data reporting contract that must be duly completed and submitted to GME according to the procedure specified by GME in the PDR User Manual. Before signing the PDR contract, the participant is required to fulfill the registration obligation provided for in Article 9 of the REMIT and obtain his/her own ACER code recognized in the CEREMP Register.

9. TO ACCESS THE DATA REPORTING SERVICE, IS IT REQUIRED ENTERING INTO AN AGREEMENT?
Yes, Participants wishing to make use of one of the data reporting services provided by GME described in paragraph 7 above, have to send the data reporting contract (whose form can be seen on http://www.mercatoelettrico.org/En/Monitoraggio/ComePartecipare.aspx) to GME, after the procedure shown in paragraph 8 above. The data reporting contract regulates the rights and obligations of the parties with respect to the use of the PDR. With regard to the performance of the data reporting service, please note that GME cannot proceed independently to the reporting of transactions on its markets against ACER without that there has been an explicit request of the Participant.

10. WHICH OPERATIONS MAY BE REPORTED THROUGH THE PDR?
Participants who have entered into a corresponding data reporting contract with GME may select to submit:
• transactions carried out on the markets managed by GME and those performed outside of them;
•  only transactions on standard contracts, only transactions on non-standard contracts[2], both;
•  only orders (performed and/or not), only transactions, both;
•  The alternatives above may be specified in the data reporting contract.

The above-mentioned alternatives may be specified in the data reporting contract.

In detail:
1)   Standardized GME contracts: MPE (MGP, MI, MPEG), MTE, MP-GAS (MGP-GAS, MI-GAS, MGS), MT - GAS;
2)   Standardized non-GME contracts: all contracts defined as standardized in accordance with IAs, treated by the participants bilaterally or through third-platforms;
3)   Standardized non-GME contracts: P-GAS;
4)   Non-standardized non-GME contracts: all contracts defined as non-standardized in accordance with IAs, treated by the participants bilaterally or through third-platforms;

11.  CAN THE DERIVATIVE CONTRACTS BE TRANSMITTED BY THE PDR?
Yes, if the loaded in the ACER format made available.

12. IS IT POSSIBLE TO SEND ELECTRICITY/ NATURAL GAS  TRANSPORT CAPACITY CONTRACTS THROUGH THE PDR?
Yes, only transportation capacity contracts concluded by participants on secondary markets, according to Article 6, paragraph 3 of the IAs. Market participants will fulfil their reporting obligation by uploading on PDR the Reports in the ACER format through the Upload service.

13. IS IT POSSIBLE TO TRANSMIT BILATERAL AGREEMENTS THROUGH THE PDR ALSO ON BEHALF OF THE COUNTERPARTY, EVEN IF IT IS NOT A GME PARTICIPANT?
Yes, as long as the Participant registered to the PDR is one of the two parties of the contract subject to the loading onto the platform through the "Upload external data service." The Participant who performs the loading on the PDR is responsible for the reporting also on behalf of the other contracting party from which he/she/it has been mandated and/or delegated.

14. HOW DOES THE DATA REPORTING WORK THROUGH THE PDR?
If, in the data reporting contract, the participant has indicated it intends to rely on GME as own RRM for transmission to ACER of those data concerning the transactions concluded on the markets of GME (Data Reporting service), GME proceeds independently to transmit its data to ACER according to the procedures, formats and the timing required by ACER.
If, in the data reporting contract, the participant has indicated it intends to rely on GME for transmission to ACER of those data concerning the transactions concluded outside the GME's markets (“Upload” service), the participant must independently load these data already in ACER format onto the PDR. This shall be promptly for their submission to ACER. In that case, GME shall then forward the reports to ACER and then store the data sent and the acknowledgment receipts sent to ACER.
By activating the "Data Reporting" service, the participant can gain access to his/her/its section of the PDR for consulting the acknowledgment receipts of ACER and the report sent by GME.

15. IN ORDER TO RECEIVE OWN DATA NECESSARY FOR REPORTING FROM GME, IS IT REQUIRED THAT ONE REGISTERS TO THE PDR?
No. Registering to the PDR is a possibility offered to the Participant, as far as this is chosen by the Participant and indicated on the data reporting contract. If a Participant does not want to make use of GME as RRM, it can free-of-charge find its data on the relevant trading platforms, which are already available in GME format. To this end, GME has made available to the Participants on its website on  http://www.mercatoelettrico.org/En/Monitoraggio/DataReporting.aspx, the supplementary information with respect to data already existing on the trading platforms necessary for the complete autonomous compilation of the reports required by ACER (i.e. UTI code, Contract ID code ...).
If a Participant wants to download such data already in ACER format, he/she/it may do so through the PDR after signing the data reporting contract by selecting the “Download” service and the payment of an appropriate fee.

16. UPON REQUEST OF ITS PARTICIPANTS, IS GME AVAILABLE TO TRANSFER THE DATA RELATED TO THOSE TRANSACTIONS CONCLUDED ON ITS MARKET DIRECTLY TO OTHER RRMs?
No. If Participants registered in the GME markets intends to make use of other RRMS to fulfill their obligation of data reporting, GME makes them available the data on transactions concluded on the markets managed by GME in the two modes described in item 14 .

17.  WILL GME PERFORM RECONCILIATION CHECKS ON BILATERAL AGREEMENTS?
No. GME will not perform any verification of reconciliation on the consistency of any data relating to bilateral contracts.

18. WHICH ARE THE PROTOCOLS AND FORMATS FOR THE TRANSMISSION TO/FROM THE PDR?
The protocols to exchange data will be consistent with the RRM requirements specified by ACER and will be aligned with the GME standards. The formats of data transmission shall be as stated by ACER in TRUM.

19.  IS GME THINKING TO OFFER A SERVICE TO THE PARTICIPANTS FOR THE CONVERSION OF THEIR DATA IN THE ACER FORMAT IN ORDER THEY CAN BE LOADED ON THE PDR?
No.

20. HOW MUCH DOES THE SERVICE COST?
The service to send ACER data about transactions made by participants on the markets regulated by GME as well as outside of the latter will be made available on payment of a yearly fixed fee, of which GME defines, by November 15 of each year, the structure and the measure giving information in the appropriate section of its institutional website. The same considerations apply for the sole Download service from the PDR of the data related to the transactions performed on the GME's markets in ACER format, formulated for Participants wishing to use a RRM other than GME.The download service only from the PDR of the data related to transactions performed on the markets of GME in ACER format, formulated for those participants wishing to use a RRM other than GME, will be offered based on the payment of a yearly fixed fee currently equal to 500 € plus VAT where applicable.

21. WILL THERE BE A GME DEPARTMENT/CONTACT SPECIFICALLY DEDICATED TO THE MANAGEMENT OF THE REMIT SERVICES?
GME makes available two email addresses to which participants can refer alternately depending on the issue delt with:

• Information on services offered through the PDR, warning on any issue on Reports, opening ticket at ACER requests , can be addressed by writing to pdr@mercatoelettrico.org.

• Information on the access to the platform (i.e. admission procedure), and any problems encountered in the management of the PDR and the relevant credentials, can be addressed by writing to abilitazioniPDR@mercatoelettrico.org.

The PDR Participant can request GME to the  opening of a ticket at ACER system according to the indications provided by GME in the PDR User Manual. 

22. WHAT ARE THE TECHNICAL REQUIREMENTS NEEDED FOR THE USE OF THE PDR?
GME has prepared a PDR User Manual listing all communication protocols and technical specifications required for proper access and use of the platform. Participants can consult the PDR User Manual on the webpage how to participate.

23. WHAT IS THE DEADLINE FOR UPLOADING THE BACKLOADING DATA ON THE PDR?
In order to ensure the fulfillment of the reporting obligation of the backloading data, as defined in Article 7 of the Implementing Acts, GME has enabled Participants to fulfill this obligation within the time set forth in the Implementing Acts through the Upload service of then PDR^[3]. Therefore at present it is no longer possible to carry out the communication of this type of contract through the PDR.

24. IS IT POSSIBLE TO CARRY OUT TESTS FOR THE REPORTING OF THE FILES?
Yes, GME provides operators of the PDR test platform to perform trials on the different features offered by the PDR. The access methods and the tracing of the credentials of the PDR test platform – diverse from those of the PDR – are described on the page How to Operate. Therefore the following email address is available: provePDR@mercatoelettrico.org.

25. WHAT ARE THE POSSIBLE IMPLICATIONS ON DATA REPORTING FOLLOWING THE UNITED KINGDOM EXIT FROM THE EUROPEAN UNION (SO-CALLED BREXIT)?

As is well known, with reference to the decisions of the European Council (XT 21053/19 and XT21105/3/18) of 18 October 2019, under the decision of the European Council (EUCO XT 20024/2/19) adopted on 30 October 2019 (https://data.consilium.europa.eu/doc/document/XT-20024-2019-REV-2/en/pdf) the deadline for the United Kingdom’s exit from the European Union has been extended to 31 January 2020. Therefore, participants that:

1. hold an ACER code associated with the registration - pursuant to article 9 of the REMIT - in the United Kingdom (i.e. ACER code with “.UK” indication) and wish to operate in the wholesale electricity and/or natural gas markets with delivery within the European Union;
2. have existing contracts for the supply or transport of electricity and/or natural gas with delivery within the European Union with participants having an ACER code associated with the registration - pursuant to Article 9 of REMIT - in the United Kingdom (i.e. ACER code with “.UK” indication).