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). https://www.acer-remit.eu/portal/home.