From the beginning of 2021 are in force the amendments to Ordinance №3 on licensing of energy activities. They impose new obligations on market participants to keep a paper and/or digital trading log of wholesale energy transactions, including withdrawn and canceled orders. The information in the trading log should include mainly bilateral transactions concluded outside of organized markets. The data that must be entered in the trading log is described in Art. 155б and 155г. of the Ordinance. It generally include the following information on the transactions:
- Companies between which the transaction is concluded
- Type of transaction
- Quantities and price
- Market on which the transaction is concluded
- Collaterals and terms
- Others
The full information to be recorded in the trading log must include at least 14 items described in the Ordinance. Such an obligation, especially given the comprehensiveness of the information to be recorded and stored, will definitely alter the operation of market participants and increase their administrative costs. Moreover, the new obligation duplicates reporting requirements under REMIT Regulation (EU) No 1227/2011 on wholesale energy market integrity and transparency (hereinafter „REMIT Regulation“) since all wholesale transactions on the BG power market already are reported to ACER under that Regulation.
During the public consultation on the proposed amendments in the Ordinance, 46 companies oppose the new obligation of keeping a trading log, including the state-owned Bulgartransgaz, Bulgargaz and Balkan Gas Hub. Despite the objections, the Energy and Water regulatory commission approved the changes in Ordinance 3 and they came into force on 31.01.2020.
The amended ordinance is available on EWRC website (only in Bulgarian): https://www.dker.bg/uploads/normative_docs/naredbi/Naredba_3_energetika_04012021.pdf
Source: State Gazette
