Ordinance № 3 on licensing the activities in the energy sector introduced the obligation of wholesale market participants to keep a log of their transactions and orders of traded products. The introduced requirements for logging and data description were essentially overlapping with the obligation to report data to the Agency for the Cooperation of Energy Regulators (ACER), thus making it more difficult for traders to administer the data. At the same time, keeping a log did not provide additional information that could not be extracted from other sources of information available to traders. For these reasons, the EWRC adopted amendments to Ordinance 3 in force as of March 29, 2022, removing the obligation to keep a logbook. Nevertheless, traders still have to keep information for 5 years on concluded transactions and orders.
The new requirement is in line with the acts of European Union, where market participants should keep this data for a period of five years and provide it upon request not only to the EWRC, but also to the Commission for Protection of Competition and the European Commission.
A novelty in Ordinance 3 is the introduction of the obligation to store and provide data on the natural gas market and data reported by transmission operators. The Ordinance also introduces a definition of “Wholesale Energy Market”.
The amendments to Ordinance 3 were published in the State Gazette: https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=171292