[ESMA 70-872942901-36 Commodity derivatives Q&A, Q&A 4.12]

Yes. Any investment firm trading in commodity derivatives contracts traded on a trading venue or in EEOTC contracts is subject to position reporting and should provide a complete breakdown of positions held on own account and on behalf of clients as the investment firm can end up holding a position even if trading on a matched principal basis. It is the investment firm’s responsibility to assess whether the transaction executed results in a change in the positions held on own account and/or on behalf of clients.