Frequently Asked Questions


  • Is JAO considered an Organized Market Place (OMP) and what services does JAO offer under REGULATION (EU) No 1227/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on wholesale energy market integrity and transparency (REMIT regulation)?

    Our answer

    JAO does not qualify as an OMP as JAO’s obligations arise via a service level agreement for explicit auctions by TSOs to act as third party on their behalf. JAO’s obligation and services are as Persons Professionally Arranging Transactions (PPAT) in wholesale energy products under Article 15 of the REMIT regulation.

    JAO is a Registered Reporting Mechanism (RRM) with reporting obligations only to TSOs. We do not report on behalf of the market participants.

    Refer also to the contract reporting details in article 3(1) (b) (i) of COMMISSION IMPLEMENTING REGULATION (EU) No 1348/2014.

  • What are JAO’s reporting obligations and the market participant’s reporting obligations?

    Our answer

    For the primary allocations, JAO will report the TSO information to ACER. This is considered to also fulfil the Market Participant’s reporting requirement based on article 8 (1) of REMIT:

    While overall responsibility lies with market participants, once the required information is received from a person or authority listed in points (b) to (f) of paragraph 4, the reporting obligation on the market participant in question shall be considered to be fulfilled.”

    For secondary allocations, JAO only reports the information on the TSO side to ACER. Market

    Participants must do the relevant REMIT reporting for returns (for resale) and transfers, if they avail of these.

    In order to know more about your company’s exact obligations you will need to contact the Agency for the Cooperation of Energy Regulators (ACER).

  • Which specific data does JAO report?

    Our answer

    JAO shall only report on behalf of TSOs details of contracts relating to the transportation of electricity in the Union. The transportation contract between two or more locations or bidding zones concluded as a result of a primary explicit capacity allocation by or on behalf of the TSO, specifying physical or financial capacity rights or obligations (file called “total allocation results” according to the IEC format 62345-451).

    Regarding transfers of physical or financial transmission rights between market participants, the reporting responsibility to ACER lies with the market participant(s).

  • Does JAO consider contracts regarding cross-border capacities concluded between JAO and a market participant as reportable under REMIT regulation (Table 3)?

    Our answer


  • Does JAO offer a copy of the reported data to market participants?

    Our answer

    JAO does not offer a copy of the reported data file, as the reported data file to ACER contains the total allocation results of all market participants.

    In case of missing or delayed data reporting, ACER will directly contact JAO in order to obtain the required information on the allocation results.

    In order to know more about your company’s exact obligations, you will need to contact the Agency for the Cooperation of Energy Regulators (ACER).

  • Are FTRs traded between TSOs and MPs in the primary market reported?

    Our answer

    Trades of FTRs on the primary market, meaning when traded by or on behalf of the relevant TSO and a Market Participant do not fall within the scope of MIFID II/EMIR and henceforth does not qualify as financial instruments thereunder.

    FTRs might be qualified as financial instruments when traded between two market participants, which could be considered as being secondary market.

    In order to know more about your company’s exact obligations, you will need to contact the Agency for the Cooperation of Energy Regulators (ACER).

  • What is JAO’s reporting obligation if a capacity is not nominated (UIOSI principle)?

    Our answer

    Physical transmission rights are subject to the “Use It Or Sell It Principle” - UIOSI principle. The Agency’s (ACER) view of transactions related to automatic return of capacity as execution of the UIOSI principle are not be considered as results of primary allocation. Therefore, this transaction is not included in the data reporting process by JAO.

  • What is Market Surveillance?

    Our answer

    As the Luxembourg regulator, Institut Luxembourgeois de Régulation (ILR) considers JAO as a person professionally arranging transactions (PPAT) and in accordance with Article 15 of REMIT, JAO had to establish and maintain effective arrangements to identify breaches of Article 3 or 5 of REMIT.

    We are hereby informing you that JAO has established a Market Surveillance Committee (MSC).

    The role of MSC is to monitor, in line with Article 15 of REMIT, potential market abuse (insider trading and market manipulation) and report on this where deemed necessary to the regulator (ILR).

    You can report any suspicious behaviour at

  • What is the Market Surveillance Committee (MSC)?

    Our answer

    Under article 15 of the REMIT regulation as Persons Professionally Arranging Transactions (PPAT) we have an obligation to notify the relevant National Regulatory authority (NRA) of any activity that we reasonable suspect to that could be I n breach of article 3 or 5 of the REMIT regulation.

    This committee ensures the integrity and transparency of the market through the identification and reporting of the suspicious activities.

    You can report any suspicious behaviour at

  • Will a market participant be informed when a breach is reported to the relevant NRA?

    Our answer

    No, a concerned market participant will not be informed if a suspicious activity as covered by article 3 and 5 of the REMIT regulation is reported to the NRA.