JAO Publishes Full Text of Nemo Link Intraday Capacity Allocation Rules (Appendix 4), Revealing Four-Auction Daily Structure and Detailed Collateral/Bidding Mechanics

Whereas the prior event confirmed only that the Nemo Link Access Rules v5 architecture included an Intraday Capacity Allocation appendix (Appendix 4) alongside Long-Term and Daily allocation, the actual full text of that appendix has now been published by JAO and reviewed. It reveals granular operational detail not previously disclosed: a four-auction daily intraday structure (NLID1 covering 00:00-06:00 delivery MTUs, NLID2 covering 06:00-12:00, NLID3 covering 12:00-18:00, NLID4 covering 18:00-24:00) each with specific gate opening/closure and Auction Specification publication deadlines; detailed Participation Agreement conclusion timelines (7+7 Working Day review cycles); collateral rules specific to intraday products including Bank Guarantee validity extending at least 30 calendar days beyond the end of the calendar month of the Product Period; pre-bidding mechanics where Offered Capacity and Credit Limit checks are deferred until bidding gate opening; default Bid provisions allowing standing bids to auto-apply to subsequent auctions; and Credit Limit verification processes tied to provisional versus final Auction Results.

These granular intraday auction mechanics govern how market participants actually manage last-minute cross-border capacity positions on the GB-Belgium interconnector in the hours and minutes before delivery, which is materially different from the long-term hedging and daily nomination processes previously analysed. The four fixed six-hour auction windows create a rigid intraday liquidity rhythm that traders must align with real-time system balancing needs, while the pre-bidding and default-bid mechanisms affect how efficiently capacity can be recycled close to delivery. Collateral validity requirements tied to the Product Period's calendar month also mean intraday participants face distinct, shorter-cycle collateral management obligations compared to Long-Term or Daily capacity holders.

The publication of this granular Appendix 4 text suggests the market design assessment should now treat Nemo Link's intraday segment as functioning close to continuous but structured intraday allocation, using four discrete Explicit Auctions per day rather than continuous trading, which is a more conservative design than some other EU intraday cross-border mechanisms. The interaction between pre-bidding (where capacity and credit checks are deferred) and the final Auction window checks could create timing risk for participants who submit large pre-bids without accounting for capacity changes announced late in the process. This detailed procedural transparency likely reduces operational ambiguity for Registered Participants already active in the Long-Term and Daily Nemo Link markets, but the appendix-specific provisions (e.g., Bank Guarantee validity tied to Product Period month-end) suggest collateral management systems must be appendix-aware rather than applying a single uniform collateral policy across all three timeframes, contrary to what might be assumed from the general Sections A-M harmonisation noted in the prior review.

Nemo Link Access Rules v5, Appendix 4 (Rules for Intraday Capacity Allocation); FCA Regulation; CACM Regulation (EU) 2015/1222; Regulation (EU) 2019/943; Regulation (EC) 543/2013 (Transparency Regulation); Directive 2019/944; Directive (EU) 2015/849 (AML); Regulation (EU) 1227/2011 (REMIT); GB Grid Code/CUSC; Balancing and Settlement Code

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