What is happening?

• ESMA have drafted reporting guidelines and validation rules for EMIR REFIT
• They invite feedback from all stakeholders before 30^th September 2021
• These will support implementation of the EMIR REFIT RTS and ITS on reporting
• Final report expected when EU Commission adopt RTS and ITS (expected early 2022)
• Go live – 18 months later (~Mid 2023: See RTS final report 346)

Document Contents;

Section	Hyperlink
1	Legislative references, abbreviations and definitions
2	Executive Summary
3	Scope
4	Purpose
5	General Principles
5.1	Transition to reporting under the draft RTS and ITS on reporting
5.2	Determining the number of reportable derivatives
5.2.1	Reportable products
5.2.2	Reporting obligation with regards to the parties involved in the trade
5.2.3	Reportability in specific scenarios
5.3	Intragroup exemption from reporting
5.4	Allocation of responsibility for reporting
5.4.1	General clarifications
5.4.2	FC trading with NFC
5.4.3	CCP
5.4.4	Funds (UCITS, AIF and IORP that, in accordance with national law, does not have legal personality)
5.5	Delegation of reporting
5.6	Reporting of lifecycle events
5.6.1	Action types
5.6.2	Sequences of action types
5.6.3	Action types and event types combinations
5.6.4	Lifecycle events and use of linking IDs (Prior UTI, PTRR ID, Subsequent position UTI)
5.7	Reporting at position level
5.8	Reporting of on-venue derivatives
5.9	Timely reporting of conclusion, modification and termination of a derivative
5.10	Mapping business events to action types and levels
5.11	UTI generation
5.12	Determining counterparty side
5.13	Identification of counterparties
5.14	Procedure when a counterparty undergoes a corporate action
5.15	Identification of products
5.16	Identification of underlying
5.17	Price, notional and quantity fields
5.18	Reporting of valuations
5.19	Reporting of margins
5.20	Identification of the trading venue
5.21	Fields related to clearing
5.22	Fields related to confirmation
5.23	Fields related to settlement
5.24	Reporting of regular payments
5.25	Reporting of other payments
5.26	Dates and timestamps fields
5.27	Reporting of derivatives on crypto assets
5.28	Reporting of complex products
5.29	Ensuring data quality by counterparties
6	Reporting per product type
6.1	Reporting of IRS
6.2	Reporting of swaptions
6.3	Reporting of other IR products
6.4	Reporting of FX swaps and forwards
6.4.1	Additional considerations on the reporting of currencies
6.5	Reporting of NDFs
6.6	Reporting of CFDs
6.7	Reporting of equity derivatives
6.8	Reporting of credit derivatives
6.9	Reporting of commodity derivatives
7	EMIR Tables of fields
7.1	Table 1 Counterparty data
7.1.1	Cleared Option between FCs
7.1.2	Cleared Option between FCs with voluntary delegation agreement
7.1.3	Non Cleared Option between FCs
7.1.4	OTC Option between NFC – and FC
7.1.5	OTC Option between NFC – and NFC +
7.1.6	OTC Contract type which requires the population of fields Direction of Leg 1 and
7.1.7	Direction of Leg 2 between FCs
7.2	Table 2 Common data
7.2.1	Reporting of action types at trade and position level
7.2.2	Other reportable details
7.3	Margin data
8	Guidelines on derivatives data management
8.1	Trade State Report
8.1.1	Introduction
8.1.2	Treatment of event date
8.1.3	Uniqueness of derivatives and special fields
8.1.4	Treatment of action type”Revive”
8.1.5	Reporting with action type ”EROR”
8.1.6	Inclusion in the TSR of notional schedules and other payments
8.1.7	Dead derivatives
8.2	Reconciliation
8.2.1	Scope of data subject to reconciliation
8.2.2	Position-level vs transaction-level reconciliation
8.2.3	Reconciliation of valuation
8.2.4	Derivatives with two legs
8.2.5	Reconciliation of notional schedules and other payments
8.2.6	Derivatives between two Systematic internalisers
8.3	Data Quality feedback
8.3.1	Rejection feedback
8.3.2	Warnings feedback
8.3.3	Reconciliation feedback
8.3.4	Revive
8.4	Data access
8.4.1	Operational aspects
8.4.2	Template form for data access
9	Annex List of questions

 

Consultation on Draft Guidelines for Reporting under EMIR (europa.eu)

 

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