For the purpose of converting thresholds that are denominated in lots into underlying units of energy derivatives, ESMA considers the monthly contracts in which most trading activity is concentrated as a baseline, each representing 1 lot.

The conversion for the 10,000 lot threshold is exemplarily demonstrated below:

For gas and base load power, the monthly contracts representing 1 lot, are considered equivalent to 720MWh (1MW[1]*24h*30days). Given that 1 MWh = 3.41[2] MMBTU and 1 MMBTU = 10 therm, the following thresholds apply:

10,000 lots = 10,000 * 720MWh = 7,200,000 MWh

10,000 lots = 10,000 * 720MWh * 3.41 MMBTU/MWh = 24,548,477 MMBTU

10,000 lots = 10,000 * 720MWh * 3.41 MMBTU/MWh * 10 therm/MMBTU = 245,484,766 therm

For peak load power, the monthly contract representing 1 lot is considered equivalent to 264MWh (1MW*12h*22days) and consequently, the following threshold applies:

10,000 lots = 10,000 * 264MWh = 2,640,000 MWh

This Q&A expands the scope of the existing Q&A on Position limits - the definition of "a lot" to also cover position reporting, without changing the approach.

Concerning gas derivatives denominated in units different from MWh, please also refer to the Q&A on lot sizes and position limits.