PLATFORM FOR THE PUBLICATION OF INSIDE INFORMATION - PIP
Frequently Asked Questions (FAQ)

In the other sections of this document the following definitions are used:
•  ACER Guidelines: ACER guidelines on the application of the Regulation 1227/2011 of the European Parliament and of the Council concerning the integrity and transparency of wholesale energy market, third edition;
•  REMIT: Regulation No. 1227/2011 of the European Parliament and of the Council of 25 October 2011 on the integrity and transparency of wholesale energy markets;
•  UMM: Urgent Market Message - message through which the Market Participant guarantees the performance to the obligation of publication of information with possible impact on energy prices in the wholesale markets;
•  Web Feed: information flow based on the XML format used for the distribution and dissemination of content interchangeably between different applications or platforms.

1.  WHAT DOES INSIDE INFORMATION MEAN?
Pursuant to Article 2 of REMIT, Inside Information means information with the following characteristics:
•  has a precise nature;
•  has not been made public;
•  relates directly or indirectly to one or more wholesale energy products;
•  if made public, it would be likely to significantly affect the prices of such products.

Art. 2 also clarifies that the inside information includes:
•  information regarding the capacity and use of facilities for production, storage, consumption or transmission of electricity or natural gas or those related to the capacity and use of LNG plants, including planned or unplanned unavailability of such plants;
•  information about the obligations of transparency defined by the EC Regulations 714/09 and 715/09;
•  information with the above-mentioned characteristics that participants are required to publish pursuant to the statutory provisions, regulations and contracts;
•  any other information that a reasonable market participant would use as the basis for its/his/her decisions.

2.  WHICH ARE THE OBLIGATIONS OF THE MARKET PARTICIPANTS WITH REFERENCE TO THE INSIDE INFORMATION?
Pursuant to Article 4 of REMIT, the market participants are required to disclose to the public in an effective and timely manner the inside information they possess on the companies or facilities that the market participant concerned, the parent undertaking or related company owns or controls or for whose operational matters the market participant or the company is responsible in whole or in part. This requirement may be fulfilled even if publication takes place in an aggregate form.

In its Guidelines, ACER specifies the preference for the use of centralized platforms for the publication of inside information. In this sense, GME has set up the Platform for the publication of Inside Information (PIP), available in the official ACER list (https://www.acer-remit.eu/portal/list-inside-platforms) of platforms found to be compliant with requirements indicated by ACER itself in its guidelines.

3.  WHAT IS THE PIP AND HOW IS IT USED?
The Platform for the publication of Inside Information (PIP) is a web platform designed by GME to allow:
•  participants of the wholesale energy market to fulfill the obligation to publish in a timely and effective way any inside information, pursuant to Art. 4 of REMIT;
•  all stakeholders to access, via a centralized, standardized and public channel, the inside information published by market operators on the PIP.
The PIP is also a tool that, through centralization and standardization of information, will enable:
• the market to have a transparency tool that increases the competition between participants;
• the market participants to fulfill, in addition to their disclosure obligation of inside information, also the guarantee of managing the information flow with ACER via Web feeds;
•  GME to fulfill more effectively the obligation to monitor and report reasonable.

4.  WHO CAN REGISTER TO THE PLATFORM? WHICH ARE THE CONDITIONS?
All entities that fall within the definition of market participant in accordance with Article 2, paragraph 7 of REMIT rules and that are properly registered with the European Register of market participants of ACER according to the provisions of Article 9 of REMIT (and therefore hold a valid ACER code), can ask to use the service of publication of inside information on the PIP.

5.  FOR THE PUBLICATION OF THE INSIDE INFORMATION ON THE PIP, IS IT NECESSARY TO EXECUTE A CONTRACT?
Yes, market participants wishing to use the service of publication of inside information on the PIP must enter into the standard contract (whose model is available for consultation only at the link https://mercatoelettrico.org/Monitoraggio/ComeParteciparePIP.aspx), which regulates the rights and obligations of the parties with respect to the use of the PIP, by filling out the appropriate web form and following the process of completing and signing the contract shown by GME in the PIP User Manual.

6.  WHICH KIND OF INFORMATION CAN BE PUBLISHED ON THE PIP?
On the PIP the market participants can upload, according to the standard format specified by ACER in its Guidelines for Urgent Market Messages (UMMS), information concerning the scheduled or unscheduled availability of their assets.
Using a dedicated text field, the market participants can also upload qualitative information or information not envisaged in the standard format.

7.  WILL GME OFFER A SERVICE FOR THE FULFILMENT OF THE OBLIGATION OF NOTICE OF THE FUNDAMENTAL DATA?
No. Pursuant to Articles 8 and 9 of the Implementing Acts, the obligation of collection and reporting communication to ACER of the fundamental data on behalf of the market participants is responsibility of ENTSO-E for the electricity sector, ENTSO-G for the natural gas, TSOs and the managers of the systems of LNG and storage.

8.  IS THE PUBLICATION OF THE INFORMATION LIMITED ONLY TO THE ITALIAN MARKET?
No. Market participants can upload information regarding the whole European market of electricity and gas.

9.  IS THERE AN OBLIGATION TO PUBLISH THE INSIDE INFORMATION ON THE PIP?
No. Participation and the publication of inside information on the PIP is a free choice of the market participant who can decide how to fulfill its/his/her obligation to publish inside information. By publication on the PIP, the market participant may fulfill its/his/her obligation of disclosure of inside information through a specific platform defined by ACER itself, on REMIT portal (https://www.acer-remit.eu/portal/list-inside-platforms).

10.  WHAT IS THE RESPONSIBILITY OF GME ON THE INFORMATION PUBLISHED ON THE PIP?
The responsibility for the selection and choice of inside information to be published, as well as the accuracy and truthfulness of the information is borne by the relevant market participant.

11. WHAT ARE THE PIP OPERATING HOURS?
Except for cases of scheduled maintenance, as provided for in paragraph 7.2 of the user manual, the PIP is always operational 365 days a year, 24 hours a day.

12.  WHICH ARE THE TECHNICAL REQUIREMENTS REQUIRED FOR THE USE OF THE PIP?
GME prepared a PIP User Manual, whereby all communication protocols and technical specifications required for the proper access and use of the platform are described. The Manual is published on the website of GME together with the model of standard contract and is available at the link https://mercatoelettrico.org/Monitoraggio/ComeParteciparePIP.aspx.

13. IS A FEE FORESEEN FOR THE SERVICE  ?
The service of publication of inside information, including all the features made available to the participants by GME within the PIP, and the viewer mode of the confidential information section available to all stakeholders are completely free.

14. IS IT EXPECTED A TESTING PLATFORM FOR MARKET PARTICIPANTS?
GME has made available to Market Participants a test platform in order to allow them to verify the correct process of uploading, downloading and publishing data. The procedure for access to testing is stated on the website of GME at https://mercatoelettrico.org/Monitoraggio/ComeOperarePIP.aspx

15.  SHALL A STANDARD FORMAT BE PREPARED FOR UPLOADING THE INSIDE INFORMATION TO BE PUBLISHED ON THE PIP?
Yes, GME will use a standard format which Participants will have to comply with for uploading their inside information, in compliance with the contents and formats indicated by ACER in the Procedure Manual and Guidelines. These also include the sending of non-standard messages in free text format.

16.  WILL A GME OFFICE/CONTACT BE SPECIFICALLY DEDICATED TO THE MANAGEMENT OF REMIT SERVICES?
Yes. Questions relating to the characteristics of the service should be addressed to pip@mercatoelettrico.org.

17.  WHAT ARE THE POSSIBLE IMPLICATIONS ON DATA REPORTING FOLLOWING THE UNITED KINGDOM EXIT FROM THE EUROPEAN UNION (SO-CALLED BREXIT)?
As is well known, with reference to the decisions of the European Council (XT 21053/19 and XT21105/3/18) of 18 October 2019, under the decision of the European Council (EUCO XT 20024/2/19) adopted on 30 October 2019 (https://data.consilium.europa.eu/doc/document/XT-20024-2019-REV-2/en/pdf) the deadline for the United Kingdom’s exit from the European Union has been extended to 31 January 2020. Therefore, participants holding an ACER code associated with the registration - pursuant to article 9 of the REMIT - in the United Kingdom (i.e. ACER code with “.UK” indication) and wishing to operate within the European Union are invited to pay attention to any provisions adopted by the relevant EU institutions, relevant for the purposes of inside information disclosure pursuant to REMIT.

18. IN CASE OF TEMPORARY UNAVAILABILITY OF THE PIP, HAS GME PREPARED A BACKUP SOLUTION?
Yes, in cae of a temporary malfunction, GME has set up a backup solution available at the link https://pip2.ipex.it. In general, through the "Other Services" section of the Web sites https://siti.ipex.it and https://siti.gme.cc, participants will be able to check the operating status of all the PIP platforms in real time.

19. WHAT iS THE TIME BETWEEN RECIVING AND PUBLISHING DATA IF THE PLATFORM IS WORKING?
The time that may elapse between communication receipt and its publication on PIP, when the platform is working, is on average less than one second.

20. IS THERE A MESSAGE OR CONFIRMATION FROM THE PIP THAT THE MESSAGE HAS BEEN PUBLISHED?
A request for publication in PIP of a new inside information, submitted by the user via portal or web service, always results in a functional Acknowledgement (FA) file, in xml format, made available in the private “XmlTransaction” section of the platform, or via web service. Therefore, no matter how long it may take between receipt and publication of the data, the market participant always has a clear and exact indication of the outcome of the request for publication of inside information.

21. IS THERE A FEEDBACK MESSAGE THAT THE DATA TO BE PUBLISHED HAS BEEN RECEIVED AND IS FORMALLY CORRECT?
Information about the outcome of each publication request of confidential details made by the user is available within the FA message, which therefore needs to be verified by the user for corrections and reloading on the platform in case of error.

22. WHAT IS AND WHAT IS THE MEANING OF MAXIMUM TIME FOR DATA PUBLICATION BY PIP?
A guaranteed maximum time to publish the message cannot be defined given that this aspect depends on factors that cannot be fully controlled by GME, such as, for example, the time of file transfer from the sender to the PIP and the load available on the platform. However, the average processing time for received messages is less than a second.

23. IN THE EVENT OF A FAILURE TO RECEIVE A RECEIPT FROM THE PIP, IS THE MARKET PARTICIPANT REQUIRED TO PROCEED TO SEND THE FILE BACK TO THE PIP?
The web service of the PIP platform shall return, in case of automatic loading through a dedicated client set up by the market participant, an initial receipt of message acceptance, prior to the outcome of the detailed processing in the FA, already in the uploading step of the message.
Therefore, if a market participant does not receive a FA file following the upload of an inside information, the market participant should consult the “XmlTransaction” section on the portal to verify that it has actually been uploaded to the platform.
If the uploaded message is not processed and therefore there is no FA message, since this is an extraordinary event, the operator must contact the IT support service active 24 x 7 by writing an email to sistemi@mercatoelettrico.org and, in copy, to pip@mercatoelettrico.org. Furthermore, the market participant can call the phone number 0680124996.
In case the message for which the operator assumes loading was not available on the PIP platform, the operator shall reload the message to the platform.

24. IN CASE OF AN AVAILABLE PLATFORM AND THEREFORE AN ACCEPTED CONNECTION, AND AFTER THAT AN UPDATE OPERATION HAS BEEN CARRIED OUT, IS THERE A LIST OF ERROR CODES IDENTIFYING THE SITUATIONS IN WHICH IT IS APPROPRIATE TO SWITCH TO ANOTHER SITE IN CASE OF A KO OUTCOME?
No, if the PIP platform returns to a FA message after a message has been uploaded, the need to publish on a backup platform is never predictable. In case of a negative FA, the market participant will have to make the correction indicated in the FA file and reload only those publications in the original file that have failed. If the problem persists, it is necessary to contact the IT support service active 24 x 7 by writing an email to sistemi@mercatoelettrico.org and, in copy, to pip@mercatoelettrico.org. Furthermore, the market participant can call the phone number 0680124996.

25. IN CASE OF RECEIPT BY THE PIP CONTAINING INFORMATION NOT TRACKED IN THE WEB SERVICE SPECIFICATION DOCUMENTS IS THE MARKET PARTICIPANT REQUIRED TO PROCEED TO SEND THE FILE BACK TO THE PIP OR TO CARRY OUT WHAT OTHER ACTIONS?
As an example, the case of "internal server error" messages is shown, followed by several other messages: It should be noted that any error messages in the FA, such as “internal server error”, must be considered temporary anomalies of the PIP platform so that it is sufficient to resubmit the message containing the inside information with only the transactions for which the error is present in the FA file. Although GME is responsible for the proper functioning of the PIP platform, by taking timely corrective action in case of malfunctions, it is represented that the operator is always required to verify his data submitted in PIP and to make any appropriate corrections in case of anomalies. Therefore, following the aforementioned checks by the market participant, if the problem persists, it will be required to contact the IT support service active 24 x 7 by writing an email to sistemi@mercatoelettrico.org and, in copy, to pip@mercatoelettrico.org. Furthermore, the market participant can call the phone number 0680124996.

26. IF ALL ACCESS CHANNELS ARE NOT AVAILABLE VIA WEB SERVICE, IS THERE A RECOVERY MODE THAT ALLOWS THE MESSAGES SENT TO BE PUBLISHED CORRECTLY?
In case of unavailability of the web service, the xml message can be submitted via the upload functionality on the platform, checking the success of the upload of the xml files on the XmlTransaction page.

27. IS THERE A FUNCTION IN THE WEB SERVICE FUNCTIONALITIES THAT ALLOWS YOU TO RETRIEVE, EVEN AFTER THE EVENT, THE ACK OF A GIVEN MESSAGE?
The FA of a web service message may be re-downloaded from the platform at any time through the ForceDownloadMessage method with the message identifier obtained during the submission of the specific xml message to the PIP platform. It should be noted that it is always possible to obtain, through the simple use of the web service method DownloadMessage, all messages not already downloaded from the platform, via web service or via portal.

28. WHAT ARE THE KNOWN CASES OF UNAVAILABILITY?
As stated in Section 7.2 of the User Manual, the PIP platform is subject to scheduled maintenance activities of less than 20 minutes on each first Tuesday of each month starting at 22:30.

29. IF THE CONNECTION IS UNAVAILABLE OR THE PLATFORM IS UNAVAILABLE (FOR EXAMPLE, A CONNECTION CANNOT BE ESTABLISHED), WHAT IS THE TIMEOUT INTERVAL AFTER WHICH THE CLIENT SYSTEM CAN DETERMINE THAT THE PLATFORM IS UNAVAILABLE, AND THEN POSSIBLY SWITCH TO ANOTHER INPUT PORT?
The connection timeout interval depends strictly on the logical strategies that are intended to be applied to the client set up by the operator and not to the GME server component. If the problem persists, it is necessary to contact the IT support service active 24 x 7 by writing an email to sistemi@mercatoelettrico.org and, in copy, to pip@mercatoelettrico.org. Furthermore, the market participant can call the phone number 0680124996

30. CAN THERE BE MALFUNCTIONS THAT ONLY CONCERN ACCESS VIA WEB SERVICE? IF THE WEB SERVICE CHANNEL DOES NOT WORK, CAN MANUAL UPLOAD STILL BE AVAILABLE?
Yes, there may be cases where the web service is not available but the platform is still available for which you can proceed with the manual upload through the PIP portal.

31. IS THE SENDING OF UNAVAILABILITY ALERT EMAILS AN AUTOMATIC OR MANUAL PROCESS?
The operator will be able to check the availability status of the PIP portals through sites https://siti.ipex.it and https://siti.gme.cc, as indicated in the PIP User Manual. GME will provide by email, as described in the PIP User Manual, further details regarding any unavailability or maintenance of the PIP platform.

32. WHAT IS THE TIME FRAME FROM THE NON-AVAILABILITY TO THE ALERT SENT BY E-MAIL?
The timelines are related to the type of communication/information you need to provide

33. IF PIP IS NOT AVAILABLE AND ONLY PIP2 IS OPERATIONAL, AFTER THE PROBLEM HAS BEEN RESOLVED, WILL PIP ONCE AVAILABLE WILL PROVIDE ALL THE INFORMATION RECEIVED AND PUBLISHED BY PIP2 FOR THE DURATION OF THE MALFUNCTION?
Yes, all portals share the same repository.

34. IF I PUBLISH ON PIP 2 AND NOT ON PIP WHAT HAPPENS? IS THE INFORMATION ALSO PUBLISHED / AVAILABLE ON PIP?
Yes, all portals share the same repository.

35. IS THERE A FUNCTIONAL CONTROL MECHANISM FOR NON-DUPLICATION OF RECORDS SENT OVER PIP AND PIP2?
This mechanism is not necessary as the repository is shared between PIP and PIP2, so only duplicate submission by the operator can result in duplication in published records

36. IS PIP2 ALWAYS OPERATIONAL REGARDLESS OF THE AVAILABILITY OF THE MAIN ACCESS PORT PIP.IPEX.IT?
YES, the PIP sites listed on the https://siti.ipex.it and https://siti.gme.cc portals are always available and usable by participants

37. WHAT SHOULD I DO IF ALL THE LINKS ON THE SITI.IPEX.IT AND SITI.GME.CC PORTALS ARE UNAVAILABLE?
In case all channels are not reachable, it will be necessary to wait for GME to restore them

38. GME PLANNED TO USE TWO ACCESS PORTS (PIP.IPEX.IT AND PIP2.IPEX.IT) TO INCREASE THE RESILIENCE OF THE PIP, AS "REDUNDANT" ARCHITECTURAL ELEMENTS PROVIDED.
The information processing facilities adopted by the PIP platform are designed to ensure the high availability of every single component (e.g., servers, storage, networking, cabling) through redundancy of equipment, power supplies, and internet connection networks. In cases where the planned local redundancy on each server farm is not sufficient, since the GME ICT systems are always redundant on at least a second Server Farm, but geographically distant, the platform failover is provided on a second Server Farm without data loss. GME databases are replicated across multiple server farms.