ACER (Agency for the Cooperation of Energy Regulators) has identified persistent data quality issues in reporting for partially matched orders (PMA - Partially Matched Orders) under REMIT (Regulation on Energy Market Integrity and Transparency) regulation.
Document Purpose: To explain current issues and proposed solutions for improving quantity information reporting on EU energy markets.
ACER has consistently observed data quality issues in Table 1 reporting for partially matched orders (PMA), including cases involving:
For PMA orders, there is inconsistency in reporting modified quantity:
| Approach | Correctness | Description |
|---|---|---|
| Reporting remaining quantity | ✅ CORRECT | Aligns with order logic |
| Reporting matched quantity | ❌ INCORRECT | Creates confusion |
| Matched quantity + additional modification for remainder | ❌ INCORRECT | Unnecessarily complicates reporting |
| Order Status | Action Type | Meaning |
|---|---|---|
| ACT (Active) | N (New) | First lifecycle event - order activation |
| ACT (Active) | M (Modified) | Order modification by price/quantity |
| MAC (Matched) | N (New) | Order matched immediately |
| MAC (Matched) | M (Modified) | Order fully matched, no longer tradable |
| MAC (Matched) | C (Cancelled) | Fully matched order cancelled (exceptional event) |
| PMA (Partially Matched) | M (Modified) | Order partially matched, remains tradable |
| PMA (Partially Matched) | C (Cancelled) | Partially matched order cancelled |
| REF (Refilled) | M (Modified) | Quantity refilled from hidden volume |
Data Field (40) - Quantity/Volume:
Single simple field with value and unit
— Does not separate matched, visible, and undisclosed quantities.
Data Field (41) - Total Notional Contract Quantity: Single simple field with value and unit — mandatory for all orders.
Data Field (19) - Undisclosed Volume: Applies to orders with HVO (Hidden Volume) condition.
The current system has no clear way to simultaneously reflect:
This leads to different interpretations and inconsistent reporting among market participants.
New description for Data Field (40) Quantity/Volume:
The quantity field now contains three components:
<quantity>
<Matched>
<value>10</value>
<unit>MW</unit>
</Matched>
<Visible>
<value>5</value>
<unit>MW</unit>
</Visible>
<Undisclosed>
<value>0</value>
<unit>MW</unit>
</Undisclosed>
</quantity>
<totalNotionalContractQuantity>
<Matched>
<value>10</value>
<unit>MWh</unit>
</Matched>
<Visible>
<value>5</value>
<unit>MWh</unit>
</Visible>
<Undisclosed>
<value>0</value>
<unit>MWh</unit>
</Undisclosed>
</totalNotionalContractQuantity>
Undisclosed Volume: Field applies to orders with HVO condition. If PMA order has no hidden volume, value 0 (zero) shall be reported in this field.
Trade reporting structure remains simple:
<quantity> <value>10</value> <unit>MW</unit> </quantity>
FAK (Fill-And-Kill) - "Fill-And-Kill" condition
T1: Order N + ACT (New active order)
| Field | Value |
|---|---|
| 40. Quantity/Volume | 15 MW |
| 41. Total Notional Contract Quantity | 15 MWh |
T2: Order M + PMA (Partially matched)
| Field | Value |
|---|---|
| 40. Quantity/Volume | 5 MW (remainder only) |
| 41. Total Notional Contract Quantity | 5 MWh |
Trade
| Field | Value |
|---|---|
| 53. Quantity/Volume | 10 MW |
| 54. Total Notional Contract Quantity | 10 MWh |
Problem: From the order record it's unclear how much was matched. Only the remainder is visible (5 MW).
| Field | Matched | Visible | Undisclosed |
|---|---|---|---|
| 53. Quantity/Volume | 10 MW | 5 MW | 0 MW |
| 54. Total Notional Contract Quantity | 10 MWh | 5 MWh | 0 MWh |
Advantage: Complete picture of order state: ✅ Matched: 10 MW ✅ Remaining visible: 5 MW ✅ No hidden: 0 MW
Iceberg order - order with HVO (Hidden Volume Order) condition, where part of the volume is hidden from market and automatically refills the visible part after execution.
| Field | Matched | Visible | Undisclosed |
|---|---|---|---|
| Quantity/Volume (Stage 1: N+ACT) | — | 15 MW | — |
| Total Notional Contract Quantity | — | 11160 MWh | — |
| Quantity/Volume (Stage 2: M+ACT with HVO) | 0 | 15 MW | 15 MW |
| Total Notional Contract Quantity | 0 | 11160 MWh | 11160 MWh |
| Quantity/Volume (Stage 3: M+PMA with HVO) | 5 MW | 10 MW | 15 MW |
| Total Notional Contract Quantity | 3720 MWh | 7440 MWh | 11160 MWh |
| Quantity/Volume (Stage 4: M+REF with HVO) | 0 | 15 MW | 10 MW |
| Total Notional Contract Quantity | 0 | 11160 MWh | 7440 MWh |
Trade: 5 MW / 3720 MWh
Advantage: Complete transparency — execution visible (5 MW → 0 after REF); visible volume refill (10 → 15 MW); hidden volume decrease (15 → 10 MW).
In the current schema, when simultaneous partial match and automatic refill from hidden volume occur, there's a dilemma: which status to indicate: PMA or REF? How to reflect both events simultaneously?
Rule: When one business decision leads to multiple simultaneous events (e.g., PMA + REF for iceberg orders), only status 'PMA' is sufficient. Indication of status 'REF' is not required.
The new structure with three components (Matched/Visible/Undisclosed) allows both events to be reflected in one record:
| Field | Matched | Visible | Undisclosed |
|---|---|---|---|
| Quantity | 5 MW (matched) | 15 MW (refilled) | 10 MW (decreased) |
For simple orders without partial match and hidden volume, it's sufficient to specify only the Visible component, as in the current schema.
| Order Condition | Description | New Structure Required? |
|---|---|---|
| FOK (Fill-Or-Kill) | Fill completely or cancel | Only upon PMA |
| FAK (Fill-And-Kill) | Fill partially, cancel remainder | ✅ YES (upon PMA) |
| IOC (Immediate-Or-Cancel) | Immediate execution or cancel | Only upon PMA |
| HVO (Hidden Volume Order) | Order with hidden volume | ✅ YES (always) |
| Iceberg Order | Iceberg order with auto-refill | ✅ YES (always) |
| GTC (Good-Till-Cancelled) | Valid until cancelled | Only upon PMA or HVO |
| Limit Order | Limit order | Only upon PMA or HVO |
| Market Order | Market order | Rarely (usually fully matched) |
| Term | English | Definition |
|---|---|---|
| ACER | Agency for the Cooperation of Energy Regulators | EU Agency for cooperation of energy regulators |
| REMIT | Regulation on Energy Market Integrity and Transparency | Regulation on energy market integrity and transparency |
| TRUM | Transaction Reporting User Manual | Transaction reporting user manual |
| PMA | Partially Matched | Partially matched order |
| MAC | Matched | Fully matched order |
| ACT | Active | Active order |
| REF | Refilled | Refilled (from hidden volume) |
| HVO | Hidden Volume Order | Order with hidden volume |
| FAK | Fill-And-Kill | Fill partially, cancel remainder |
| FOK | Fill-Or-Kill | Fill completely or cancel |
| IOC | Immediate-Or-Cancel | Immediate execution or cancel |
| GTC | Good-Till-Cancelled | Valid until cancelled |
| OMP | Organised Market Place | Organised market place |
| XSD | XML Schema Definition | XML schema definition |
The document contains reporting examples for various trading scenarios:
Section 1: Order and trade reporting via Table 1
Section 2: Non-standard contract reporting via Table 2
Section 3: Transportation contract reporting via Tables 3 and 4
ACER Official Documentation:
ACER's proposed changes to the quantity information reporting schema for partially matched orders represent a significant step forward in improving data quality and transparency on European energy markets. While implementation will require effort from all market participants, the long-term benefits of improved market oversight, reduced operational risks, and process standardization significantly outweigh short-term costs. The success of this initiative depends on active participation of all stakeholders in the consultation process and careful preparation for implementation of new rules.