About MIDL

MIDL exists because reports a system should produce are still being put together by hand: hours of needless work, and a risk nobody sees until a regulator does.

What we do

• Readiness Check (free): shows which rules apply and where your gaps are likely to be.
• Diagnostic: confirms which gaps are real and checks each one is closed once you've fixed it.
• Managed Reporting: takes the reporting off your hands and keeps up with the rules for you.

Where this comes from

MIDL is run by Kelvin Cheung, an ICAEW chartered accountant and an associate member of the Association of Corporate Treasurers. After qualifying he joined a corporate treasury, doing financial instruments reporting and hedge accounting for the derivatives a business uses to manage its risks. Most of it was firefighting the software that was supposed to produce the outputs, and ferrying data between systems by hand because nothing else worked.

When EMIR arrived in 2014, those same derivatives had to be reported to a regulator for the first time. No system was built to do it, so the submissions were compiled by hand: tedious, unauditable, and quietly risky in a way nobody upstream could see.

From there he moved into the finance functions and back offices of commodity trading businesses, including financial reporting, and the pattern held everywhere. Most recently he has worked in digital transformation, redesigning finance processes and systems at global scale, and building the tools himself in Python.

The system was only ever the symptom. The real problem was that nobody senior enough was accountable for it.

As long as something plausible came out of the end, management did not know or care how it was produced. Across more than fifteen years, the same thing kept happening: reasonable people propping up broken processes, and no way to tell whether the numbers going to a regulator were actually right.

Why that matters for REMIT

A REMIT report goes wrong in one of two places: in how the rules were turned into requirements, or in how the data moved. Those two halves are almost never looked at by the same person. MIDL's principle is that one person has to understand both.

Turning the rules into requirements

Kelvin spent more than five years advising on IFRS in-house, at an oil and gas supermajor and at the trading arm of one of the world's largest gas producers: across the standards, and in particular IFRS 9, financial instruments and commodity trading. That is the work of reading a standard as written, following how the standard-setter consults, adopts and then interprets it, and working out what it means in practice for a business's processes, data and reports.

EU energy regulation runs the same way. ACER consults, the Commission adopts, and regulators publish guidance and Q&As. The obligation sits in the detail, and in the dates.

Knowing how the data actually moves

• How commodity trades are captured and accounted for
• How ETRMs record a trade from booking to settlement, and how a set-up choice or a workaround can leave gaps that only show up in the reports downstream
• Tracing a data flow end to end and finding the point where it breaks
• Building the software and pipelines that fix it, rather than recommending someone else does

The consultants who understand the business usually can't build the fix. The engineers who can build it usually don't understand the business, so they can't tell what the output should have been.

Underneath sits a working REMIT reference base: scope, obligations, thresholds, deadlines and exemptions, each checked against the regulations themselves and the regulators' own publications, and re-checked when they change. The readiness check is built on it.

Kelvin Cheung is an ICAEW chartered accountant (ACA) and an associate member of the Association of Corporate Treasurers (AMCT), with more than 15 years across corporate treasury, financial reporting and advisory, digital transformation, and commodity trading back offices.