This section contains answers to some frequently asked questions on REMIT received at Bulgartransgaz and is provided for information purposes only. The Q&As does not constitute legal, technical or professional advice of any nature and may not be relied upon as such.

In no event shall Bulgartransgaz be liable for any damages of any kind, including, but not limited to, direct, indirect, general, special, incidental, or consequential damages arising out of any use of the information obtained using this site.

REMIT (Regulation on energy market integrity and transparency) is abbreviation of Regulation (EU) No 1227/2011 on wholesale energy market integrity and transparency.

REMIT defines a framework for the monitoring of wholesale energy markets. The objective is to detect and to deter market manipulation. Energy trading is screened at EU level to uncover abuses. Market integrity and transparency are essential for well-functioning energy markets and for promoting the confidence of market participants and final consumers.

REMIT applies to trading in wholesale energy products and introduces a sector-specific legal framework for the monitoring of wholesale energy markets in EU by establishing rules prohibiting abusive practices and market manipulations.

The Regulation envisages:

- Article 9 – Establishing a European register of market participants based on national registers – by introducing a requirement market participant entering into transactions, which are required to be reported to the Agency in accordance with Article 8(1), to register with the national regulatory authority;

- Article 8 – Data collection by the Agency for the Cooperation of Energy Regulators (hereafter Agency or ACER) of information for assessing and monitoring wholesale energy markets;

- Article 7 – Market monitoring by ACER in close collaboration with national regulatory authorities aimed to detect and prevent trading based on inside information and market manipulation;

- Article 4 – Inside information disclosure by the market participants;

- Articles 3 and 5 – Prohibition of insider trading and market manipulation.

Regulation (EU) No1348/2014 lays down rules for the provision of data to the Agency implementing Article 8(2) and (6) of Regulation (EU) No 1227/2011, defines the details of reportable wholesale energy products and fundamental data and establishes appropriate channels for data reporting including defining timing and regularity of data reports.

Article 9 paragraph 1 requires market participants entering into transactions which are required to be reported to the Agency in accordance with Article 8(1) to register with the national regulatory authority in the Member State in which they are established or resident or, if they are not established or resident in the Union, in a Member State in which they are active.

The contracts for transportation of natural gas within the EU fall into the scope of the definition for wholesale energy product required to be reported to the Agency in accordance with Article 8(1).

Article 9 paragraph 1 obliges market participants referred to in Article 9 paragraph 1 to submit the registration form to the national regulatory authority prior to entering into a transaction which is required to be reported to the Agency in accordance with Article 8(1).

For more information on the requirements for registration as market participant and access to the portal for market participants registration used by the Bulgarian NRA, please visit the web-sites of ACER CEREMP and EWRC.

Based on the national registers, ACER establishes European register of market participants (ACER CEREMP).

In line with the requirements of Article 9 paragraph 3 of Regulation (EU) No 1227/2011, ACER determined the format for registration of market participants, published on 26 June 2012 through  ACER Decision 01-2012.  

The format requires mandatory provision of information for field 113 „EIC of the market participant“, if such code is available. 

The EIC of the market participant is a mandatory element in the electronic data exchange based on the industry standard edig@s for communication between the network users and transmission system operators.

The electronic formats for REMIT data reporting of the gas transmission system operators in accordance or Article 8 paragraph 1 of Regulation (EU) No 1227/2011 are based on edig@s standard and require identification of the participants in the relevant transactions solely by EIC codes.

Having regard to the above and taking into account the provisions of Article 10 paragraph 2 of Regulation (EU) No 1348/2014, the market participants’ registration in accordance with of Article 9 paragraph 1 of Regulation (EU) No 1227/2011 must be supplemented by an EIC that shall be used subsequently in the transactions reportable under REMIT and in the REMIT reporting process.

The same EIC must be used in the transactions and the electronic data interexchange between the relevant market participant and Bulgartransgaz.

The EIC of the market participant provided in ACER CEREMP must be used by the network user for its registration on the Regional Booking Platform (RBP) and Bulgartransgaz’s Commercial Dispatching Platform (CDP).

At the beginning of 2021, ACER intends to activate new validation rules on the reported gas and electricity transportation data.

The rules will require and check whether the reported EIC type-X which is used to identify a market participant in the reported data for the capacity allocation transaction corresponds to the EIC provided by the market participant during its registration in accordance with article 9 paragraph 1 of Regulation (EU) No 1227/2011.

Upon the activation of the rules, all reported records containing EIC codes as identifiers of market participants that are not present in the ACER CEREMP will be rejected.

It is obligatory that Bulgartransgaz’ network users be registered in accordance with article 9 of Regulation (EU) No 1227/2011 and their registration in the European register of market participants be supplemented by an EIC that must be used in the transactions and the electronic data exchange between the relevant network user and Bulgartransgaz.

For granting access to Bulgartransgaz’ information system CDP and the auctions for capacity allocation at Bulgartransgaz’ points on RBP, we perform verification and comparison of the registration data provided by the relevant network user for access to the system against the contents of the relevant parameters in the public records of ACER CEREMP, ENTSO-E CIO EIC database, EC VIES VAT validation tool, as follows:

Verification for:

- ACER code – fulfillment of the requirement for registration in compliance with article 9 of Regulation (EU) No 1227/2011;

- EIC in the market participant’s profile in ACER CEREMP – provision of EIC during the registration in compliance with article 9 of Regulation (EU) No 1227/2011;

- Correspondence of the ACER code, provided during the registration for access to the relevant information system with the market participants’ ACER code published in ACER CEREMP;

- Correspondence of the EIC code, provided during the registration for access to the relevant information system with the market participants’ EIC code published in ACER CEREMP;

- Correspondence of the EIC code, provided during the registration for access to the relevant information system with the market participants’ EIC code published in ENTSO-E CIO EIC database;

- Correspondence of the VAT number, provided during the registration for access to the relevant information system with the VAT number provided by the network user for the contract for access and transmission through Bulgartransgaz’ network;

- Correspondence of the VAT number, provided during the registration for access to the relevant information system with the VAT number published in ENTSO-E CIO EIC database next to the name and EIC code of the company; 

- Correspondence of the VAT number, provided during the registration for access to the relevant information system with the VAT number published in EC VIES VAT validation tool next to the name of the company.

The reporting channels are defined by article 6 of Regulation (EU) No 1348/2014.

Market participants could report data to ACER directly, if registered and authorized by the Agency as registered reporting mechanism (RRM), or through third-party acting on behalf of the market participant. 

When a market participant uses the reporting services of a third-party RRM(s), this(ese) RRM(s) shall be listed as Delegated party in market participant’s profile in ACER CEREMP. 

In November 2019, ACER temporarily suspended the registration of new reporting systems (RRMs).

Details of contracts relating to the transportation of natural gas as a result of a primary explicit capacity allocation and the relevant fundamental data are reported only by the TSO or by third-party on behalf of the TSO. 

Full list of the registered reporting mechanisms authorized by ACER is available on ACER REMIT Portal.

Bulgartansgaz EAD is registered as market participant (ACER Code: A0001038B.BG) according to the requirements of article 9 paragraph 1 of Regulation (EU) № 1227/2011 and as Registered Reporting Mechanism (RRM) type TSO.

Bulgartansgaz EAD, as RRM type “TSO” is entitled to report to ACER only its own data. The company is not authorized to report on behalf of third parties, nor to report data different from what was specified during the RRM registration process and indicated on the ACER REMIT Portal in the “List of RRMs with data types”.

Bulgartransgaz is reporting to ACER the following types of data:

- Directly reporting as RRM to ARIS - the fundamental data required by article 9 paragraph 2 of Regulation (EU) No 1348/2014 on day-ahead nominations, final re-nominations of booked capacities and allocated quantities specifying the identity of the market participants involved;

- Directly reporting as RRM to ARIS - the data required by article 3 paragraph 1 (a) of Regulation (EU) No 1348/2014 in relation to supply contracts of natural gas for Bulgartransgaz’ needs concluded outside an organized market place;

- Through the Regional Booking Platform (RBP) - the data required by article 3 paragraph 1 (b)(i) of Regulation (EU) No 1348/2014 regarding the contracts relating to the transportation of natural gas concluded as a result of a primary explicit capacity allocation on RBP;

- Directly reporting as RRM to ARIS - the data required by article 3 paragraph 1 (b)(i) of Regulation (EU) No 1348/2014 regarding the contracts relating to the transportation of natural gas concluded before 7 April 2016 but still valid by 7 April 2016, as well as contracts relating to the transportation of natural gas concluded as a result of a primary explicit capacity allocation outside RBP (non-standard contracts for transportation);

- Through ENTSOG - the data published by Bulgartransgaz on ENTSOG Transparency Platform as referred to in points 3.3(1) and 3.3(5) of Annex I to Regulation (EC) No 715/2009. ENTSOG reports data to ACER in line with the requirements of article 9 paragraph 1 of Regulation (EU) No 1348/2014;

- Through GIE - the data published by Bulgartransgaz on the GIE Aggregated gas storage information (AGSI+) platform. GIE reports data to ACER through the AGSI+ platform in line with the requirements of article 9 paragraph 7 of Regulation (EU) No 1348/2014.

Regarding the requirements of article 4 of Regulation (EU) No 1227/2011 for public, effective and timely disclosure of inside information, Bulgartransgaz publishes on its web-site, ENTSOG transparency platform (ENTSOG TP) and on GIE AGSI+ platform (AGSI+) the data required by Regulation (EC) No 715/2009 and the network codes.  

The information which has not been made public, which relates, directly or indirectly, to one or more wholesale energy products in so far as this information is likely to have a significant effect on the prices of wholesale energy products, relevant to the capacity and use of facilities for storage and transmission of natural gas owned by the company, including planned or unplanned unavailability of these facilities is disclosed by publication of Urgent Market Messages in accordance with the requirements of ACER for format and content of those messages.

According to ACER Guidance on the application of Regulation (EU) No 1227/2011, the inside information shall be disclosed by publication of Urgent Market Messages on a Platform for Inside Information Disclosure approved and registered by ACER.

ENTSOG Transparency Platform is accepted by ACER as platform for disclosure of inside information by the EU gas transmission system operators.

Bulgartransgaz publishes UMMs on ENTSOG Transparency Platform. In addition, the information is published in the section UMM Messages on the corporate web-site.

EIC is abbreviation of Energy Identification Coding scheme.

The coding scheme is standardized and governed by ENTSO-E with the aim to facilitate the cross-border energy trading, by ensuring effective and reliable identification scheme of objects, elements and activities of the energy market, needed for the electronic data interexchange between the parties.

The EIC coding scheme ensures a unique identification for all objects related to the European markets for electricity and gas - balancing zones, production facilities, storage facilities, LNG terminals, entry/exit points of electricity or gas networks, market participants and etc.

The energy identification codes (EIC) are used to enable information interchange between parties for the electricity or gas energy market in Europe

The EIC codes could be with local or international significance.

The EICs used in the REMIT process and/or for the publications done in compliance with the Transparency Regulation must be with international significance. 

A legal entity having an EIC code with an international significance may use the code on every natural gas and electricity market in Europe. The possession of an EIC code does not give an access to a market. To participate in a market, it is necessary to fulfill the requirements and the rules of the respective regulatory bodies.

The EIC codes are issued and administered by the Central Issuing Office (CIO) and/or by Local issuing Offices (LIOs), authorized by the CIO.

The CIO is under the direct responsibility of ENTSO-E. It ensures the management of the central registry (publication of all EICs with international significance) and the acceptance of LIOs.

Bulgartransgaz EAD is registered as Local issuing office (LIO) for EIC codes by the ENTSO-E (as CIO) under number 58. 

More details on the EIC codes you can find in the EIC Reference Manual and on the web-page http://www.eiccodes.eu

Information on the activities of Bulgartransgaz LIO and the EIC codes issued by Bulgartransgaz is available in the web-section EIC codes on the internet site of the company.

The electronic formats for REMIT reporting are established by ACER in accordance with article 10 paragraph 3 of Regulation (EU) No 1348/2014. 

The EIC codes are the only acceptable identifiers for indicating the “Delivery point or zone” of the commodity in the electronic formats for reporting of contracts for supply (REMITTable 1 and REMITTable 2).

REMITTable 1 and REMITTable 2 schema allow the usage of EIC, ACER code, MIC, LEI or GLN code for identification of the reporting entity and the market participants in the reported transaction.

The electronic formats for reporting of contracts for transportation of natural gas and the relevant fundamental data (Nomination monitoring, Contract Market Monitoring and Gas Capacity Allocations schema) are based on the industry standard edig@s. Those schemas allow the usage of EIC codes as the only acceptable type of identifiers for the infrastructure objects and market participants in the reported transaction: network users, TSOs, reporting entity, connection point and etc.

The reporting of contracts for supply of natural gas, falling into the scope of the wholesale energy products reportable under REMIT, is market participants’ obligation.

In line with the requirements of article 6 paragraph 1 of Regulation (EU) No 1348/2014, the details for wholesale energy products executed at organised market places including matched and unmatched orders shall be reported to the Agency through the organised market place concerned, or through trade matching or trade reporting systems.

In the answer to Question III.2.25 from the document ACER Questions & Answers on REMIT, ACER precise that “Market participants cannot report details of wholesale energy products executed at organised market places by themselves, regardless of whether they register as an RRM or not. Article 6(1) of Commission Implementing Regulation (EU) No 1348/2014 defines the reporting channels for the reporting of details of wholesale energy products executed at organised market places, including matched and unmatched orders, to the Agency. Therefore, it is the Agency’s understanding that reporting channels for the details of wholesale energy products executed at organised market places are: organised market places, trade matching systems or trade reporting systems. The organised market place where the wholesale energy product was executed or the order was placed shall, at the request of the market participant, offer a data reporting agreement”.

In accordance with article 6 paragraph 3 of Regulation (EU) No 1348/2014, market participants or third parties acting on their behalf shall report details of contracts referred to in article 3(1)(a) (supply contracts), which have been concluded outside an organised market place and fall into the scope of the wholesale energy products reportable under REMIT.

In accordance with article 6 paragraph 3 of Regulation (EU) No 1348/2014, market participants or third parties acting on their behalf shall report details of contracts referred to in 3(1)(b)(ii):

“Contracts relating to the transportation of electricity or natural gas in the Union between two or more locations or bidding zones concluded between market participants on secondary markets, specifying physical or financial capacity rights or obligations, including resale and transfer of such contracts”.

When Bulgartransgaz’ network users conclude contracts for transportation of natural gas through Bulgartransgaz’ network on secondary market on the Regional Booking Platform (RBP) and/or have REMIT reporting agreement with RBP, the reporting of the secondary market transactions could be performed by RBP on behalf of the relevant market participant(s). For that purpose, FGSZ/RBP (A00009913.HU) shall be indicated as Delegated party in market participant’s profile in ACER CEREMP.

If Bulgartransgaz’ network users conclude contracts for transportation of natural gas through Bulgartransgaz’ network on secondary market outside the Regional Booking Platform (RBP) and/or do not have REMIT reporting agreement with RBP, the reporting of the secondary market transactions could be performed directly by the market participant, if it has been registered as registered reporting mechanism (RRM) by ACER, or through third-party acting on behalf of the market participant.  

When a market participant uses the reporting services of a third-party RRM(s), this(ese) RRM(s) shall be listed as Delegated party in market participant’s profile in ACER CEREMP.

Bulgartransgaz is not authorized to report data on behalf of third parties and does not offer services for reporting of contracts for transportation of natural gas concluded on the secondary market.

The electronic formats for reporting of details for the supply contracts (REMITTable 1 and REMITTable 2) require identification of the location of commodity delivery in the attribute “Delivery point or zone”.

In 2018, ACER activated validation rules in the ACER REMIT Information System (ARIS) verifying the content of the  schema attribute “Delivery point or zone” against a special “List of accepted EICs for REMITTable 1 and 2” established by ACER, published on – ACER REMIT portal – TRUM, Annex VI.

ARIS rejects any REMITTable 1 or 2 report file that contains in the attribute “Delivery point or zone” an EIC not present in the “List of accepted EICs for REMITTable 1 and 2”.

According to ACER guidance and recommendations defined in TRUM, Annex VI, when the point of delivery of natural gas is not an interconnection point between transmission system operators, storage facility or LNG terminal, the  EIC of the balancing zone where the commodity changes hands shall be indicated as “Delivery point or zone”.

For instance, if the delivery point of a contract for supply of natural gas is an internal exit point of Bulgartransgaz’ network, (i.e. АGRS Kardam - 58ZC001P01KARD-3) or an internal entry point to Bulgartransgaz’ network (i.e. GMS Galata - 21Z000000000375C) or a VTP, the filed “Delivery point or zone” of the relevant REMIT report file must contain the EIC of the balancing zone to which the particular point belongs.

REGULATION (EU) № 1227/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 October 2011 on wholesale energy market integrity and transparency
COMMISSION IMPLEMENTING REGULATION (EU) № 1348/2014 of 17 December 2014 on data reporting implementing Article 8(2) and Article 8(6) of Regulation (EU) № 1227/2011 on wholesale energy market integrity and transparency
OTHER RELEVANT INFORMATION on the requirements and ACER guidance on REMIT implementation is available on ACER REMIT Portal.

For questions regarding market participants' registration with the relevant National Regulatory Authority (NRA), the Centralised European Register of Market Participants (ACER CEREMP) or any technical problems with CEREMP, please contact the relevant NRA.