1. Update on Transparency Obligations Martin Reisner Junior Adviser, Transparency ENTSOGs Transparency Workshop Brussels – 11 September 2012

2. Content 2 >CMP Background Decision Transparency >REMIT Background Obligations Latest activities >Challenges

3. Congestion Management Procedures I 3 >Initial proposal from the European Commission in late 2010 >EC Stakeholder Workshops and public consultation during 2011 >Formal comitology process completed during early 2012 2 Gas Committee meetings held in January and April >Publication in the Official Journal of the European Union on 24 August 2012 following decision by both Parliament and Council not to oppose adaption: Background

4. Congestion Management Procedures II 4 >ENTSOG has identified 2 parts: Procedures intended to mitigate contractual congestion o Oversubscription / buy-back scheme o Firm day-ahead use-it-or-lose-it mechanism o Surrender of contracted capacity o Long-term use-it-or-lose-it mechanism Amending Chapter 3 of Annex I to Regulation (EC) No 715/2009 o Additional information to be published Content of the Commissions Decision

5. Congestion Management Procedures III 5 >Additional information to be published occurrence of unsuccessful, legally valid requests for firm capacity products with a duration of one month or longer including the number and volume of the unsuccessful requests in the case of auctions, where and when firm capacity products with a duration of one month or longer have cleared at prices higher than the reserve price where and when no firm capacity product with a duration of one month or longer has been offered in the regular allocation process total capacity made available through the application of the congestion- management procedures laid down in points 2.2.2, 2.2.3, 2.2.4 and 2.2.5 per applied congestion-management procedure Transparency

6. Congestion Management Procedures VI 6 >Information has to by published starting from 1 October 2013… >…in a downloadable format that has been agreed between transmission system operators and the national regulatory authorities on the basis of an opinion on a harmonized format that shall be provided by the Agency and that allows for quantitative analyses… >…on one Union-wide central platform… >…established by ENTSOG… >…on a cost-efficient basis. Transparency

7. REMIT I 7 >Regulation of the European Parliament and of the Council on wholesale energy market integrity and transparency >REMIT covers trading of commodity and financial instruments for financial and non- financial counterparties >Market participants – including transmission operators – are subject to new reporting obligations regarding commodity trading, e.g. for balancing purposes. Many reporting obligations also refer to storage and LNG regasification data. >Due to different interpretation ACERs 1 st Guidance Focusing mainly on electricity Background

8. REMIT II 8 >Reporting of inside information What is an inside information? How should it be reported and to whom? >Publication of transparency information TSOs: Annex 1 of Reg. 715 (Transparency Guidelines) Outages / unplanned maintenance has to be published immediately Is balancing energy or fuel gas subject of inside information? >Public Consultation on Registration Format Registration before participating the market Just once at any NRA ACER will/can publish a list of market participants Obligations for Market Participants

9. REMIT III 9 >Public Consultation on Records of Transactions >ENTSOGs key messages Data security Avoidance of Double Reporting TSOs obligation covered by Reg. 715 >ACER Workshop on 19 July >Publication of Discussion Paper 2 Options: o Disclosure of information through (existing) transparency platform (Reg. 715/714) o Nomination of platforms for disclosure by NRAs on a regional/national level >ENTSOGs response TSOs fulfill obligation by publishing information on ENTSOGs Transparency Platform Latest activities

10. Future Challenges 10 >All TSO fully publish information according to requirements >Uncertainties for future development… …REMIT …other regulations >Reporting to different entities the same set of data a different / individual set of data >Coordination for higher efficiency is needed …on a national level …of obligations due to different regulations

11. Thank You for Your Attention ENTSOG -- European Network of Transmission System Operators for Gas Avenue de Cortenbergh 100, B-1000 Brussels EML: WWW: www.entsog.eu Martin Reisner Junior Adviser, Interoperability/Transparency martin.reisner@entsog.eu Do you have further questions?