ACER REMIT FAQ for Standard & Non-Standard Contracts
Key terms and practical questions about reporting of standard and non-standard contracts under ACER REMIT.
Definition of Standard & Non-Standard Contract
Please note: The definition was amended with effect from 29 April 2026.
Under the recast REMIT Implementing Regulation:
ACER PRACTICAL INTERPRETATION (FOR REPORTING)
- Transactions concluded on an OMP → treated as standard
- Transactions concluded outside an OMP (OTC) → treated as non-standard
Regulatory update (effective 29 April 2026)
The EU has adopted a recast REMIT data reporting framework (Commission Implementing Regulation (EU) 2026/256). From 29 April 2026, ACER clarified updated definitions and reporting timelines for standard vs non-standard contracts.
Transition example: If a non-standard contract is concluded on 28 April 2026 (one day before entry into force of the recast REMIT IR), the one-month reporting timeframe still applies, and the transaction needs to be reported at the latest on 28 May 2026. Whilst if the transaction occurs on 29 April 2026, it will have to be reported at the latest by 13 May 2026 (T+10 business days under the new framework).
Most provisions apply with a transition period, but reporting parties should already align their processes with the new timelines.
Key timeline changes:
How to decide what to report
1
WHERE WAS THE TRANSACTION CONCLUDED?
Concluded on an OMP
→ Report as standard (T+2)
Concluded outside an OMP (OTC)
→ Report as non-standard (T+10)
2
ARE PRICE AND QUANTITY DEFINED AT THE TIME OF REPORTING?
OTC deals with defined (agreed) price and quantity
→ Report using Table 1 (REMITTable1) within T+10 business days
→ Use BILCONTRACT in Contract Name (Data Field 22) where applicable
Framework contracts (price/quantity not yet known)
→ Report the framework contract using Table 2 (REMITTable2) within T+10 business days
→ When price and quantity become known, report the related EXECUTION using Table 1, linked to the Table 2 Contract ID
UNCERTAINTY ABOUT ‘LOOK-ALIKE’ CONTRACTS AGREED OTC
In practice, reporting parties may not always have full visibility of specifications of products traded on organised marketplaces. If you conclude a contract OTC and you are uncertain whether it is identical to an OMP-traded product, treat it as an OTC/non-standard case for reporting timelines and select Table 1 or Table 2 depending on whether price and quantity are known.
Executions, outright volume and price, and deadlines
Executions under non-standard/framework contracts are reported once the delivered quantity and final price are confirmed by the parties (often after delivery and commercial reconciliation).
When an execution specifies at least an outright volume and price:
- → Report it with Table 1 (REMITTable1) as
EXECUTION - → Report it within the non-standard/OTC timeline, i.e. no later than 30 calendar days (one month) after the execution/confirmation or, where applicable, after the invoicing date, in line with TRUM v7.0 (sections 3.1.5, 3.1.6 and 3.3.2).
Transaction timestamp (Field 30)
Field 30 (Transaction timestamp) should indicate when each market participant confirms the price and quantity of the execution.
If the exact matching execution time is not known to both parties: report the date and, as the schema uses datetime, you may use the default time 00:01:00 UTC.
Lifecycle events
Lifecycle events are changes after initial reporting and must also be reported within the applicable deadlines:
OMP / standard: T+2
OTC / non-standard: T+10
OTC / non-standard: T+10
Action types in electronic formats:
Important: Action type E cannot be used for business decisions (e.g. price/quantity changes) — use M instead.
Note: This FAQ collection has been compiled from various sources and reflects our understanding. It is provided for informational purposes only and is not legally binding. We do not take any legal responsibility for the accuracy or completeness of the information. For legal or regulatory matters, please consult a professional.