Frequently asked questions
The Finnish version of the questions and answers shall prevail over the English version.
What do I have to do to register as a market participant?
The registration process consists of the following steps:
- Basic information (registration form https://gasgridportal.fi/register)
- Signing the role specific framework agreement with the TSO.
- Provision of collateral (depending on role)
- Information exchange tests (depending on role)
You can find a description of and more information about the registration process at Gas Market Code and Information Exchange Guidelines.
What is an EIC and where can I get one?
Shippers and traders operating on the Finnish gas market are required to have an EIC (Energy Identification Code. Instructions about EICs and how to apply for one can be found at: https://kaasumarkkina.fi/eic-codes/
What is a GLN and where can I get one?
Distribution System Operators and Retailers are required to have a Global Location Number (GLN) of the GS1 system as their Participant identifier. You can obtain a GLN at GS1 Finland. More information about how GLNs are formed and created can be found at Gas Market Code and Information Exchange Guidelines and GS1 Finland’s websites.
Can a Distribution System Operator decide the end part of the GLN when determining the first part is based on the company prefix?
Operators can decide the end part of the GLN themselves. Read more about the GLN Participant identifier and its content on the GS1 Finland website.
A Retailer and Distribution System Operator must use its GLN as its participant identifier. If the same participant (same taxation unit) acts in multiple market roles (e.g. DSO and Retailer), the participant must use in its information exchange GLNs with the same company prefix but with a different running consecutive number. The participant must notify the GLNs it uses to the TSO. The participant must also notify which GLN is used in each market role.
You can find more information in chapter 4 of the at Gas Market Code and Information Exchange Guidelines.
Will a list of registered market participants be published online?
During the course of November 2019, the TSO will ask by email if Shippers, Traders and Retailers who have done the registration allow to publish the name of their company on a list that will be published on the TSO’s website. TSO will ask about the publication of the name of the company in the same way also later when TSO have confirmed new registration applications. Names can be removed from the list by emailing a request to the TSO.
How will a market participant be visible to others in the TSO’s Portal?
As stated in the terms of access to the Portal, a market participant’s basic information is as a rule visible to all market participants who can, because of their market role, form supply relationships with the market participant concerned. If a market participant wishes to prevent its basic information from being seen by other market participants, the market participant must separately request the TSO to ensure that its basic information is not visible to other market participants in the Portal.
Can a Trader trade/sell gas to metering sites in the distribution network?
A Trader is a market participant that carries out wholesale trading in gas. A Trader may not operate on the retail market. On the distribution/retail market side, Retailers operate as the seller and the DSO is responsible for distributing gas to the end users.
How is the gas supply secured in situations of major capacity fluctuations?
A Distribution Network End User must have a Retailer, who in turn must have at least one Shipper who supplies gas to the Retailer. It is advisable for the End User to notify the Retailer of its gas requirements so that the Retailer can agree supplies with the Shipper and further enable the Shipper effecting the supply to prepare for major capacity fluctuations. A Shipper have possibility to obtain within-day capacity during the gas day which gives shipper ways to react to the changes in consumption requirements. Gas flows physically to your metering site irrespective of whether or not the Shipper supplying you with gas has ordered sufficient capacity. In such situations, the Shipper will incur penalty payments because it exceeded its ordered capacity. Contracts between market participants ultimately determine who is finally responsible for the costs incurred.
Who pays loss gas in a situation where all metering sites in the Distribution Network are Daily Read Metering Sites? Does the Shipper charge the Distribution System Operator direct, and how is the Shipper chosen just for delivering this loss gas?
The DSO is responsible for obtaining the loss gas in the Distribution Network. If all Daily Read Metering Sites are read remotely, the Shipper and DSO can decide on the “supply” and pricing of loss gas between themselves. The DSO itself can specify the Shipper supplying the loss gas.
Who pays with regard to metering sites without agreement if gas is nevertheless consumed there? Who does the gas supplied to this metering point belong to in this case?
Gas consumption at sites where there is no agreement is comparable to losses. This means the Distribution System Operator must obtain that gas from the same party as it obtains its loss gas, i.e. from the Retailer with delivery obligation or possibly direct from the Shipper where all the metering sites in the Distribution Network concerned are Daily Read Metering Sites.
If I want to buy gas from Estonia acting as a Shipper there, are there differences between acting as a Shipper in Finland?
If you want to buy gas as a Shipper in Estonia, you must register with the Estonian Transmission Network Operator Elering AS’s system. The gas market principles in Estonia are similar as in Finland but there are differences in market rules (e.g. in capacity booking windows). Estonia and Latvia are aiming for a common balancing zone from the start of 2020. This will result in the same market rules being applied in these countries. You can find the market rules for the Estonia-Latvia area at https://elering.ee/sites/default/files/2019-10/Common_network%20rules_EE-LV.pdf.
How are payment obligations determined between Shippers/Traders operating as a Balance Responsible Party and Balance Group member?
A Shipper operating in the roles of a Balance Responsible and a Balance Group member have the same rights to order capacity for itself. Shippers are responsible to the TSO for the capacity they order.
A Balance Responsible Shipper/Trader is responsible to the TSO for payments arising from imbalances both with regard to the balance positions of Shippers/Traders operating as their own as well as Balance Group members. A Balance Responsible Party has a possibility for economies of scale since the balance positions of Balance Group members can cancel each other out when one is long and the other is short. When the Balance Group is in balance, the Balance Responsible Party does not incur any imbalance charges but, depending on the membership terms of its Balance Group, may collect imbalance charges from Balance Group members in order to obtain more balancing payments from Balance Group members than the Balance Responsible Party itself has to pay the TSO.
The Balance Responsible Party obtains information about the balance position of its own Balance Group as well as the balance positions of Balance Group members so that the Balance Responsible Party can invoice Balance Group members based on the imbalance. The TSO charges only the Balance Responsible Party for the imbalance, whereas invoicing between the Balance Responsible Party and Balance Group members is a matter between these parties.
Which market roles require collaterals to be provided and for what purpose?
You can find guidance on this in the Gas Market Code and Information Exchange Guidelines. All Shippers, Balance Responsible Traders, Transmission Network End Users and DSOs are subject to creditworthiness requirements. Creditworthiness requirements are satisfied by providing collaterals in accordance with the principles described below:
Shippers and Balance Responsible Traders
A Shipper must meet the creditworthiness requirements set by the Transmission System Operator in order to be able to order capacity and to obtain capacity rights. For capacity orders, the TSO must be provided with collateral the value of which at any given time shall be three times the amount of the highest monthly capacity invoice actually sent for the past twelve months.
A Balance Responsible Shipper and Balance Responsible Trader must also meet the creditworthiness requirements set by the TSO to be able to operate as a Balance Responsible Party. A Balance Responsible Shipper or Balance Responsible Trader is further required to provide collaterals to a value that covers the Balance Responsible Party’s outstanding invoices at any given time for imbalance charges and estimated imbalance charges that have not yet been invoiced by the Balance Responsible Party, including a 10% security margin for monthly fluctuation in imbalance charges.
Transmission Network End Users
If a Transmission Network End User has not applied to the Finnish Tax Administration as a registered user, the Transmission Network End User must meet the Transmission System Operator’s creditworthiness requirements to be able to operate as a Transmission Network End User. Security must be provided to the Transmission System Operator to the value of the highest monthly invoice for natural gas and biogas taxes and security of supply charges for natural gas and biogas delivered by the Transmission System Operator over the past 12 months.
Distribution System Operators
Collaterals must be provided to the Transmission System Operator to the value of the highest monthly invoice for natural gas and biogas taxes and security of supply charges for natural gas and biogas delivered by the Transmission System Operator over the past 12 months.
Shipper Framework Agreement: “A Shipper must set a security the value of which at any given time shall be three times the amount of the highest monthly capacity invoice actually sent during the past calendar year.” How will this be determined during the first year?
When the market opens, the creditworthiness requirement will be applied as if all Shippers registered as Market Participants from July 2019 would be new participants with no earlier capacity agreements. In this case, a check will be made in conjunction with the request for a capacity order to establish whether or not the Shipper has adequate collaterals. An assessment will be made on the basis that the order made would constitute the first invoice, which would be compared to the size of the existing collaterals.
Which kind of collaterals will the TSO accept?
The Transmission System Operator will accept as collaterals on-demand guarantees of an A-rated (Moody’s or Standard & Poor’s) financial institution registered in an EU Member State and the market operator’s cash deposits into a bank account designated by the Transmission System Operator with System Responsibility: Bank account means a collateral account with an A-rated (Moody’s or Standard & Poor’s) financial institution registered in an EU Member State and a pledge agreement in respect of which is submitted to the Transmission System Operator with System Responsibility. If a market participant wishes to use some other financial institution (e.g. a credit insurance company) than a bank to provide the security, this is also acceptable to the TSO provided that the financial institution is registered in an EU Member State and has an adequate credit rating.
Is security required for value added tax (VAT)?
How much collaterals does the TSO require from Shippers?
For Shippers, the collateral requirement is based on two needs:
- Capacity (below is a sample calculation based on the assumption that the Shipper orders annual capacity of 100 MW to the entry zone)
The total capacity needed is: 100 MW x 8 760 h = 876 000 MWh
The annual capacity price in the entry zone is: €1.04859/kWh/day/year x 1 000 kWh/MWh / 365 d/y = €2.8728 / MWh
Total capacity price is: 876 000 MWh x €2.8728 / MWh = €2 516 572.80
Per month €2 516 572.80 € / 12 = €209 714.40
Thus, the minimum collateral requirement needed is: 3 x €209 714.40 = €629 143.20
- Imbalance (applies to Balance Responsibility Parties)
In addition to collaterals for capacity, a Balance Responsible Party is required to provide collateral for an imbalance. As soon as an imbalance is formed, the collateral must correspond to the aggregate of the outstanding invoices for imbalance charges and imbalance charges that have not yet been invoiced together with a 10% security margin.
Points 1 and 2 mention a minimum level – it is advisable to provide adequate collateral for own activities to prevent surprises occurring when, for example, ordering capacity.
Can a Balance Group buy transmission capacity as a joint purchase by a Balance Responsible Party?
Capacity cannot be bought for a Balance Group but for a Shipper itself. In other words, as a Shipper you cannot use the capacity bought by another Shipper without it having been transferred to you through a transfer of capacity rights. A Balance Group, therefore, has nothing to do with capacity.
What time do sales and allocation agreements begin and end?
Sales and allocation agreements end and begin at 7 am (at the same time as the Gas Day serving as the balance period changes).
Who will provide Gas Exchange services starting from January 1, 2020?
Gasum Oy and the Lithuanian gas exchange operator UAB GET Baltic have entered into an asset purchase agreement whereby Gasum’s gas exchange operator Kaasupörssi Oy will cease trading on January 1, 2020 when the Finnish gas market opens up to competition. At the same time, GET Baltic, a gas exchange owned by UAB GET Baltic and already operating in the Baltics, will start its operation in Finland. GET Baltic will provide the Finnish market gas exchange services in the open market starting on January 1, 2020. For more information, see the media release.
We advise contacting GET Baltic direct in matters relating to gas exchange services in 2020.
Will trade notifications be sent automatically from GET Baltic to the TSO so that Shippers or Traders don’t need to submit them twice?
GET Baltic will make trading notifications to the TSO on behalf of the trader so that all data will be automatically sent to the TSO.
Capacity of Balticconnector Interconnection Point
Capacity of Balticconnector IP will be offered implicitly. What does this mean in practice?
In implicit capacity allocation, both the transmission capacity and the corresponding volume of gas are allocated at the same time. In the case of Balticconnector, the Nominations confirmed by the TSO function automatically as a request of corresponding amount of capacity. This means that the Shipper needs only to nominate at Balticconnector to obtain the correct amount of capacity. Nomination deadlines can be found in the Rules for Gas Transmission. The Balticconnector capacity allocation mechanism is pro rata. If the available capacity is smaller than the aggregated amount of Nominations, Nominations are reduced on a pro rata basis so that the allocated capacity equals to the reduced Nomination. In case of Balticconnector, capacity is allocated to Shippers on the third hour at the latest after the Nomination and Renomination window has been closed.
Part of Balticconnector’s capacity is offered implicitly through Nominations (as described above) and part of capacity is offered via the exchange. The exchange forms pricelists of buy and sell quotes with Finnish and Baltic states’ quotes in order of price. Finland, Estonia and Latvia constitute a common tariff area and consequently there will be no tariffs between these countries. This is why Balticconnector capacity has no tariff either. Tariffs on the border between Lithuania and Latvia will be automatically included in the exchange pricelist. In this way, the market participant buying or selling the gas does not know whether the gas it is selling or buying comes from a Finnish, Estonian-Latvian or Lithuanian market area.
The implicit allocation model offered via the exchange makes it possible also for a Trader to buy or sell gas from/to Baltic states through Balticconnector, albeit unaware because of anonymous gas exchange trading. This is possible, because the exchange operates as a trade counterparty over BC as if it is a party booking capacity, in which case the Trader does not participate in ordering capacity in accordance with the market rules.
What is the amount of capacity offered in Balticconnector at the start of 2020?
On May 7, 2019, Elering published indicative values for the technical capacity in Balticconnector at the start of 2020. https://dashboard.elering.ee/en/umm/single/1457. Virtual counterflow, however, means that the commercial amounts of capacity may deviate from the technical capacity.
Does the TSO with System Responsibility expect there will be congestion in Balticconnector?
The TSO has no knowledge on the basis of which the likelihood of congestion could be assessed. The TSO cannot speculate on the issue.
How will the TSO with System Responsibility act if congestion occurs in Balticconnector?
- According to the rules of capacity allocation, the pro-rata principle will be used in situations of congestion (if the available capacity is smaller than the aggregated amount of Nominations). This means that Nominations will be reduced so that capacity is allocated on the basis of reduced Nominaitons.
- If congestion is caused by an unforeseen shortage of technical capacity, the TSOs will do their best to avoid reducing Nominations that have already been confirmed. The TSOs will use the operational balancing account or balancing services as flexibility measures in such short-term congestion situations.
- If congestion occurs frequently, the TSOs will initiate discussions with the regulatory authorities to assess alternatives to solve the problem.
Exchange of information
Where can I find more information about AS4 and Edig@s connections?
You can find more information about AS4 and Edig@s connections in the ”Edig@s XML 5.1 guideline for Finland” document and, for example, by viewing the ”Nominations and trade notifications using Edig@s and connecting to AS4” presentation material from the information event on October 7, 2019.
Where can I find more information about the Portal’s API?
You can find out about the Portal’s API by viewing the ”Portal and its API interface” presentation material from the information event on October 7, 2019. Parties who have completed the registration form can access the Portal’s Staging environment, through which they can familiarize with the description of the API interface.
Where can I find more information about the processes in the retail market when switching the retailer and when moving to new address?
The rules for these processes in the retail market can be found in the Rules for Gas Distribution. You can find more information about these processes by reading the “Gas datahub: data management and contract processes” presentation material from the information event on October 7, 2019.
What does the point “The ICT system has been approved” mean in the rules? What is the approval protocol like and how long does the approval process take?
Chapter 3.2 of the Gas Market Code and Information Exchange Guidelines describes the trial usage of information systems and testing of information exchange. Chapter 6.1 describes the Shipper’ and Trader’s electronic messages that, with regard to Nominations and Trade Notifications, act as an alternative to using the TSO’s web portal.
Does each Shipper and Trader need to arrange an Edig@s message connection to the TSO’s system?
It is not compulsory for Shippers and Traders to use Edig@s messaging. Exchange of information on the wholesale market is centered on the TSO’s Portal, which can be used through a user interface and/or the API interface. Alternatively, Shippers and Traders may also use electronic messages (Edig@s XML versio 5.1 and AS4 protocol) for their Nominations and Trade Notifications. Shippers and Traders who choose to use electronic messages, are required to comply with the information exchange standards of the Transmission System Operator with System Responsibility (national application of Edig@s), and successfully pass the information exchange tests set by the TSO. The TSO opened the Edig@s testing service in September 2019. You can test the Edig@s/AS4 connection by emailing a request for instructions to firstname.lastname@example.org.
The Finnish version of the questions and answers shall prevail over the English version.