FAQ - Clarifications on the information collection procedures - Resolution 155/2026/R/gas

Annex A to Resolution 155/2026/R/gas establishes a 15-day deadline for the notification of new contracts and related amendments, applying it uniformly also to short-term (ST) LNG contracts and long-term (LT) FOB LNG contracts, for which the delivery point is not necessarily located in Italy. From what date does this deadline run for these types of contracts, where the decision to allocate a cargo to Italy is taken after the contract has been executed (FOB transactions, in particular, are structured with flexible destination clauses, and the delivery point is determined on the basis of logistical and commercial assessments made after the fifteen-day period following contract execution)?

As a preliminary point, it should be recalled that the monitoring activity provided for under Article 7(5) of Decree-Law No. 21 of 21 March 2022 concerns “contracts for the procurement of gas volumes intended for the Italian market.”

Accordingly, the submission of contractual documentation relating to LNG procurement is subject to the obligations established by the above-mentioned Decree-Law, in accordance with the implementing provisions of Resolution 155/2026/R/gas, insofar as the gas procured is destined, even only in part, for Italy and is injected into Snam Rete Gas National Gas Transmission Network.

Therefore, in light of the above considerations, for ST LNG contracts and LT FOB LNG contracts with a delivery point outside Italy, the 15-day notification period shall be deemed to commence on the date on which delivery at the receiving Italian regasification terminal is confirmed by that terminal. The contractual documentation shall be submitted only once, rather than for each individual delivery, in accordance with the procedures established by Resolution 155/2026/R/gas, upon the first delivery to Italy.

With regard to the historical data flow, should data relating to long-term LNG procurement contracts with FOB delivery in the country of origin and liquefaction, or DES delivery, without an obligation to deliver LNG to Italy, nevertheless be submitted on a monthly basis?

With regard to the historical data flow, should data relating to long-term LNG procurement contracts with FOB delivery in the country of origin and liquefaction, or DES delivery, without an obligation to deliver LNG to Italy, nevertheless be submitted on a monthly basis?

Section D of Annex B to Resolution 155/2026/R/gas requires the historical data flow to be submitted exclusively by Certified Electronic Mail (PEC). How is this requirement to be fulfilled by foreign operators that do not meet the eligibility requirements for obtaining a PEC address (e.g. a valid Italian tax identification number or an Italian VAT registration number)?

Since the use of a Certified Electronic Mail (PEC) address is intended to protect the sending operators, communications may alternatively be sent to info@arera.it.
Please note that communications must be sent strictly to only one of the two addresses (protocollo@pec.arera.it or info@arera.it), and not to both. Furthermore, the subject line of the communication shall strictly correspond to that specified in Sections E and D of Annexes A and B, respectively, namely: “DL 21/22 – flusso documentale”, “DL 21/22 – flusso storico”.

Resolution 155/2026/R/gas specifies, in point 2, that compliance with the reporting obligations established by Decree-Law No. 21/22 shall be fulfilled exclusively through the reporting formats set out in Annexes A and B to the Resolution.

Consequently, any modification and/or addition to these templates is not acceptable, as it cannot be processed and is therefore deemed equivalent to a failure to submit the required information.

In this regard, it should be noted that the xlsx templates include “Notes” fields where any information that cannot be encoded according to the prescribed formats may be provided.
 

Section F of Annex B to Resolution 155/2026/R/gas provides that previously submitted data may be corrected with the first subsequent submission.

It should be clarified that a correction replaces the entire record (i.e. the entire row) previously submitted. Accordingly, all fields of the xlsx template must be completed when submitting a correction, exactly as for a new submission, with the only difference being that the value “Correction” shall be selected in the Communication_Type field.

The Month and Year fields shall indicate the reporting month and year to which the previously submitted data being replaced relate.

Where a contract is denominated in USD and the currency “$” has been selected in the Currency field of the historical data flow template, must all cost data also be reported in USD? Which exchange rate should be used if the costs are instead reported in EUR?

Yes. All cost data must be reported in the currency selected in the Currency field.

Where the contractual data are denominated in USD, but the reporting entity chooses to report the cost data in EUR, the applicable exchange rate shall be the customs exchange rate published by the Italian Customs (Agenzia delle Dogane e dei Monopoli). It is available at: https://www.adm.gov.it/portale/dogane/operatore/e-inoltre/cambi-doganali.