What Is Delegated Reporting for OTC Derivatives?

After 21 October 2024, firms can continue to delegate their reporting, however the safe harbour provisions have been mostly removed from the ASIC rules. This means that firms will need to implement greater monitoring and reconciliations of their ASIC trade reporting.  ASIC has advised there will be further consultation on these provisions prior to the new rules coming into place however at this stage it is not clear if the position will move back closer to the current state in time.

We encourage firms to build an understanding of how to conduct regular reconciliations and monitoring. TRAction have compiled resources for both clients and non-clients to assist with this process.

Prior to 21 October 2024 (the commencement of the new ASIC trade reporting rules), a reporting entity received a safe harbour benefit when it appointed one or more persons (each a delegate) to report OTC derivatives on its behalf. This delegate may be a counterparty, a central counterparty, a trading platform, a service provider, a broker or any other third party.