HEnEx SA (“HEnEx”) requires its trading members to contribute to its own reporting requirements as set forth by the Financial Energy Market Rulebook (Derivatives Market) and MiFID II/MiFIR provisions.
MiFID II Position Reporting and MiFIR Transaction Reporting
According to Article 58 of Regulation (ΕΕ) 2014/65/EU (“MiFID II”), Members and Participants of trading venues must report to the trading venue on a daily basis a complete breakdown of their positions in commodity derivatives, as well as those of their clients and the clients of those clients and so on down to the end client.
Moreover, according to Article 26 of Regulation (EU) No. 600/2014 on Markets in Financial Instruments (“MiFID II”) trading venues shall report details of transactions in financial instruments traded on their platforms for non-investment firms.
Investment firms which execute transactions in financial instruments are required to submit transaction reports to the National Competent Authority (NCA) of the trading venue. The reports shall be made to the competent authority either by the investment firm itself, an Approved Reporting Mechanism (ARM) acting on its behalf or by the trading venue through whose system the transaction was completed.
Investment Firms which are HEnEx Members can fulfil their transaction reporting obligations through Athens Stock Exchange SA (“ATHEX”), which is authorized from the Hellenic Capital Market Commission (“HCMC”) as an Approved Reporting Mechanism (ARM). More information is available here.
HEnEx Derivatives Market Members should submit the relevant MiFID II Position Reporting/MiFIR Transaction Reporting forms, which can be found here.
MiFIR Order Record Keeping
Article 25 of MiFIR dictates that trading venues shall keep at the disposal of the competent authority, for at least five years, the relevant data relating to all orders in financial instruments which are realized through their systems. Members using short codes (identifiers) in the OASIS Trading System for HEnEx Derivatives Market during the trading session, will be required to upload a set of mappings, so that the short codes used in a trading session can be mapped to the respective Long Codes, as ESMA dictates, through Members Portal.
According to REMIT Regulation 1227/2011 Art.8, all the Market Participants shall provide the Agency for Cooperation of Energy Regulators (ACER) with a record of their wholesale energy market transactions, including orders to trade. The submission of such records to ACER is performed through a Registered Reporting Mechanism (RRM).
HEnEx, being approved as RRM, provides REMIT Reporting Services to (a) Market Participants who intend to use HEnEx as RRM, (b) Market Participants who intend to use a third party RRM but are trading members of HEnEx and (c) Market Participants reporting their bilateral contracts.
HEnEx has developed a dedicated application accessible through its Members Portal to enable Market Participants fulfil their REMIT Reporting obligations. Market Participants, which are also HEnEx Trading Members, may access the dedicated application and either monitor the automatically submitted reports of their transactions concluded in HEnEx markets to ACER or download a copy of their market data and make use of a third party RRM for the reporting.
Our services cover also the reporting of bilateral transactions and/or orders/transactions executed in a foreign OMP of Market Participants that intend to use HEnEx as RRM.
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