1. Who is obliged to register in the Montenegrin Register of Wholesale Electricity and Gas Market Participants?

In accordance with the provisions of Law on the Surveillance of Wholesale Electricity and Gas Market, the obligation to register in the  Register of Wholesale Electricity and Gas Market Participants has every natural or legal person, or entrepreneur, as well as transmission and distribution system operator, who in Montenegro in terms of the Law: issues orders for trading in wholesale energy products, makes purchase transactions / sells electricity or participates in auctions of cross-border capacity;

2. Does the obligation to register also apply to the affiliated parties? 

In accordance with the provisions of Law on the Surveillance of Wholesale Electricity and Gas Market the obligation to register in the Register of Wholesale Electricity and Gas Market Participants has every natural or legal person, or entrepreneur, as well as transmission and distribution system operator, who participates in the electricity market in Montenegro, including their affiliated parties which are participating in the market in Montenegro. 

3. Is there a fee for registration in the Register of Wholesale Electricity and Gas Market Participants?

There is no registration fee or any other fee for registration in the Register of Wholesale Electricity and Gas Market Participants.

4. What are the obligations of the market participants regarding the monthly reporting of the Agency?

In accordance with the article 13 of the Montenegrin Law on the Surveillance of Wholesale Electricity and Gas Market, Market Participant is obliged, by the 15th of the current month for the previous month, to submit to the Agency following data on executed transactions with wholesale energy products:

–         on purchased and sold wholesale energy products;

–         on the price and quantity of purchased and sold wholesale energy products;

–         on participants in executed transactions;

–         on the date and time of execution of transactions.

5. Is the market participant obliged to report to Agency, if there was no executed transaction in the previous month?

If the Market Participant did not perform transactions in the previous month, he is obliged to submit a notification to the Agency by the 15th of the current month for the previous month, that he did not perform any transactions.

6. What does the abbreviation “L.S” on the first page of the Registration Form mean? 

Abbreviation “L.S” means “Locus Sigilli” (Latin) translated as “the place of the seal”, where the company seal should be placed. If the company doesn’t use the seal, then it’s not obliged to insert it. An electronic signature is acceptable, too.

7. Will the Agency register the company in the Register of Wholesale Electricity and Gas Market Participants, if the field “Inside Information Disclosure” or some other field from the Registration Form, is not filled? 

The Agency will not reject the application for registration of the company in the Register of Wholesale Electricity and Gas Market Participants, if the field “Inside Information Disclosure” or another field that is not crucial for the registration process, such as the lack of an official company website, is not filled.

However, in accordance with Article 9 of the Law on the Surveillance of Wholesale Electricity and Gas Market, inside information can only be published by using electronic systems listed by the Agency for the Cooperation of Energy Regulators (ACER) ) https://www.acer-remit.eu/portal/list-inside-platforms Non-disclosure of inside information, including disclosure of inside information on the web page of the Market Participant, or on any other web page which is not on the ACER list, represents the basis for imposing a fine in accordance with Article 19 of the Law on the Surveillance of Wholesale Electricity and Gas Market.

8. Can a market participant change the data from the Register of Wholesale Electricity and Gas Market Participants?

The Market Participant may change any data from the Register of Wholesale Electricity and Gas Market Participants, which is submitted in the Registration Form.

In fact, in accordance with article 7 paragraph 2 of Law on the Surveillance of Wholesale Electricity and Gas Market, the Market Participant is obliged to notify the Agency of any change, within 24 hours of the change. 

9. Whether insider information can be published on the website of Market Participants. 

In accordance with Article 9 of the Law on the Surveillance of Wholesale Electricity and Gas Market, inside information can only be published by using electronic systems listed by the Agency for the Cooperation of Energy Regulators (ACER) ) https://www.acer-remit.eu/portal/list-inside-platforms

Publishing inside information only on the website of the Market Participant or on another platform, which is not listed on the ACER list, is not acceptable and will be considered a non-disclosure of inside information.

Non-disclosure of inside information represents the basis for imposing a fine in accordance with Article 19 of the Law on the Surveillance of Wholesale Electricity and Gas Market.