Agency has indicated that where the gas is delivered at an LNG or a gas storage facility, then the EIC W code for that facility should be reported.
(FAQ on transaction reporting, Question 2.1.42 )
The reporting of contracts for the supply of liquefied natural gas (LNG) should not be different than any other contract for the supply of natural gas. The only difference between a contract for the supply of natural gas at a balancing area and the contract for the supply of liquefied natural gas at the LNG terminal is the reporting of the delivery point. While market participants have to use EIC Y code for reporting the delivery of natural gas at balancing areas, EIC W code should be used when the delivery is in the LNG terminals.
(FAQ, Question 3.1.2)
Contract outside of EU
Contracts for the supply of LNG before the entry flange of an EU LNG regasification terminal are not subject to transaction reporting. (For example an exchange of title on the high seas outside the EU.)
Cargos traded under such contracts are subject to the reporting of fundamental data provided once the cargo is unloaded at an EU LNG regasification terminal.
If the cargo – once bought on the high seas outside the EU under this type of contract is re–traded by the buyer at or after the entry flange of an EU LNG regasification terminal, then the transaction related to the new contract will be subject to reporting.
(FAQ, Question 3.1.21)
The transportation contract from the regasification terminal to the gas terminal does not need to be reported. There are currently no requirements for the reporting of transportation contracts involving locations that are not balancing zones.
(FAQ, Question 4.2.20, 3.1.22 – 3.1.26, 3.1.49)
Virtual Gas Storage Contract
Are Virtual Gas Storage contracts reportable under REMIT?
Insofar as virtual gas storage contracts are not contracts for the supply (or transportation) of natural gas, they are not reportable under REMIT.
However, contracts for the supply of natural gas within storage and LNG facilities are reportable contracts. For instance, when market participant A sells gas to market participant B within a storage or LNG facility, transferring the ownership of the gas, this is a reportable contract.
(Questions and Answers on REMIT, Question 1.1.8)
Contract with Delivery in the Union
Are contracts for the supply of liquefied natural gas (LNG) with delivery in the Union covered by the scope of REMIT?
Contracts for the supply of LNG, where delivery is in the Union, are wholesale energy contracts pursuant to Article 2(4)(a) of REMIT.
(Questions and Answers on REMIT, III.3.34)
Delivery of LNG into the European Union
What constitutes delivery of LNG into the European Union?
As far as liquefied natural gas (LNG) contracts are concerned, the Agency considers any importation or offloading of liquefied natural gas in any LNG facility (including flanges that connect the LNG vessel to the LNG terminal) as ‘delivery in the Union’ as far as the delivery of the product takes place in the European Union.
In the situation described above, assuming the delivery of the liquefied natural gas is in the European Union, both parties to the contract will need to register with the relevant National Regulatory Authority/ies as the contract is reportable to the Agency.
Reload-contracts at a regasification terminal or at a vessel where the delivery of the product is not the European Union are not reportable.
(Questions and Answers on REMIT, III.3.36)
Delegate the Reporting Obligation
Are RRMs allowed to report fundamental data directly to ACER on behalf of market participants for “Unloading and Reloading of LNG” and for “Amount of gas stored”?
The market participants can delegate the reporting obligation to LSO/SSOs respectively or to any other registered RRM.
(Questions and Answers on REMIT, III.4.2)