Collaboration with your liquidity providers and other counterparties is key to ensuring your regulatory transaction reporting is accurate.
The implementation of EU EMIR Refit, UK EMIR Refit and the ASIC and MAS Rewrites means that there are a number of extra items relating to transaction reporting which should now be taken into account when putting together agreements with liquidity providers.
See below examples of issues which should be at the forefront:
UTI reporting / generation / sharing
It is important to understand the UTI waterfall that applies and who the generating entity is. The process of UTI generation should be dealt with in your derivative trading documentation or in separate bilateral agreements.
Both parties to the trade should be submitting the same UTI in their regulatory transaction reports. When time frames are tight and there are thousands of trades between two counterparties (e.g. you and an LP), having a simple (and preferably automatic) system for attaching the UTI to trades so that they match on both sides is critical.
Some regimes also have specific additional requirements. Under MAS Rewrite for example, there is an expectation that the counterparties have in place internal policies and procedures regarding the UTI generation process.
Pairing and matching resolution processes
These should be provided for in your documentation or bilateral trade reporting or delegate agreements. You can see further information about what fields in the transaction reports of both counterparties need to match and how this process works in our articles:
When you receive a report from the trade repository showing fields that don’t match between yourselves and your counterparty, do you know who to contact at your counterparty to get this resolved? What is the mechanism between yourselves to fix the processes going forward so that this doesn’t turn into a regular occurrence? These are important points to establish up front before you start trading so that any issues can be resolved as quickly as possible.
LEI renewal
Regulators will reject trades, if for example, the fields below contain details of an entity with a lapsed LEI:
- in EMIR reports – ‘reporting firm ID’
- in MiFIR reports – ‘executing entity ID’
If a trade is rejected, it means a resubmission of the trade will be required after the renewal of the LEI. Therefore, timely renewal of LEIs for both the broker and the LP is crucial to avoid disruptions in your reporting obligations. Note this is not a requirement for counterparty 2 under the ASIC and MAS regimes.
You can read more about LEI status requirements in our article.
UPI provision and sharing
The party who is to create, obtain and share UPIs from the UPI Library as maintained by ANNA DSB could be specified in written documentation. This will ensure there is a clear process which operations teams can refer to. These provisions will also be useful in the event of regulatory scrutiny about your reporting arrangements.
Specified mechanism for sharing details
If TRAction or another firm has been appointed as your reporting delegate, we suggest having provisions in your agreements allowing TRAction to contact and liaise with both parties where necessary. For example, where matching isn’t occurring. This will allow the reporting delegate to resolve these issues prior to submission where possible. It will also allow the reporting delegate to identify where there are trades between two of its clients and build in pre-submission checks to identify components of trades which are not going to pass the ‘pairing and matching’ requirements so that they can be resolved earlier.
If parties do not wish to coordinate the sharing of key trade information, this is a service that TRAction can provide in its delegate capacity for its clients where it is assisting in reporting for both parties.
Delegated reporting, not delegated responsiblity
If you have appointed your counterparty to carry out delegated reporting for you, you need to ensure that this is actually and accurately taking place. Under most transaction reporting regimes, the reporting entity retains the ultimate responsibility for reporting conducted on their behalf (rather than the responsibility sitting with the delegate performing the reporting).
Ensure that your reporting delegate appointment letters or agreements are current and that you are undertaking regular reviews and reconciliations of what is being reported on your behalf.
Single-Sided Reporting (ASIC)
Do you have any SSR letters in place? If you do, you should review the current requirements (which were updated in October 2025) and ensure you are using up to date single-sided reporting letters (for more information see our article here).
Other things to review are whether you have access to reporting done in other jurisdictions or by your counterparty eg. the level of involvement in the process of checking the trades reported through single-sided reporting or if you receive regular confirmation of the process? There are minimum requirements for ‘regular enquiries’ of your counterparties which need to be met to be eligible for the relief.
