JAO's GR-MK 'explicit' allocation rulebook revealed as the pan-EU Harmonised Allocation Rules for Long-Term Transmission Rights, not a bespoke daily scheme

The fuller text of the draft rulebook previously characterized as a GR-MK daily explicit capacity allocation document is now shown to be the standard pan-EU 'Harmonised Allocation Rules for Long-Term Transmission Rights' (HAR) issued under Article 51 of the FCA Regulation (EU) 2016/1719. The HAR template was originally approved by ACER in 2017 (Decision 03/2017) and subsequently amended in 2019, 2021 and 2023 (Decisions 14/2019, 15/2021, 18/2023); the current draft is based on ENTSO-E/TSOs' amendment proposal submitted to ACER on 27 March 2025, with a document base date of 17 September 2025, now surfaced as the GR-MK-applicable 'under approval' annex. The substantive architecture (participation agreement, collateral forms, credit limit, bidding/auction mechanics, PTR nomination, fallback, curtailment/force majeure compensation, invoicing, dispute resolution) matches what was previously described, but the underlying product scope is confirmed to be annual/monthly Long-Term Transmission Rights allocated via auction (and subsequent transfer/return), not a daily-only explicit regime. The document remains released for information and pending NRA approval, unchanged from prior state.

This clarifies that GR-MK cross-zonal capacity access for forward hedging will be governed by the same ACER-approved, pan-EU-harmonised LTTR template used across other EU borders, rather than a border-bespoke daily auction design. That means future EU-wide HAR amendments (as approved by ACER) will automatically propagate to this border via its annex, and market participants seeking annual/monthly hedging products on GR-MK will be subject to the standard use-it-or-lose-it, nomination, and Day-Ahead-Firmness-Deadline-based curtailment compensation regime. It also corrects the product/timeframe classification of this border's instrument set, which affects how participants should size collateral and credit-limit exposure relative to monthly/annual (not daily) settlement cycles.

The newly visible preamble (ACER Decision history, 27 March 2025 TSO amendment proposal, 17 September 2025 base document date) suggests this GR-MK annex is simply attaching the border to the latest EU-wide HAR amendment cycle rather than creating a bespoke daily product. This plausibly explains the earlier-noted tension between a November 2026 publication date and a stated 1 January 2026 application: Article 5(2) of the HAR ties the delivery period start to '1 January in the subsequent year following the adoption' of the HAR, so if the underlying EU-wide HAR amendment was adopted/approved in 2025, a 1 January 2026 delivery-period start would be mechanically consistent with the template rather than evidence of backdating. Nonetheless, the GR-MK-specific NRA approval date remains undisclosed, so the border's actual binding entry-into-force and practical go-live timing are still unresolved pending that approval, and my reclassification of this instrument from day-ahead to forward/long-term is an inference from document content rather than an explicit border-specific product statement in the visible text.

FCA Regulation (EU) 2016/1719, Article 51 and Article 52(2)-(3) (Harmonised Allocation Rules basis); ACER Decision 03/2017 and amending Decisions 14/2019, 15/2021, 18/2023; Regulation (EU) 2019/943; CACM Regulation (EU) 2015/1222; Regulation (EU) 543/2013; Directive (EU) 2019/944; REMIT Regulation (EU) 1227/2011; Directive (EU) 2015/849 (AML); eIDAS Regulation 910/2014

National Regulatory Authorities approval of GR-MK Harmonised Allocation Rules for Long-Term Transmission Rights

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