Until UK Refit
Monday, 30 September 2024

EU Refit
Monday, 29 April 2024

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Refit By Numbers

Current Number of Fields
Increase in Fields
Fields After Refit
Years Since EMIR Came Into Law
ISO format #


Didn't we already do EMIR Refit?

EMIR first came into effect in 2012 with a reporting commencement in 2014.  Since then there have been a number of updates to the regime, often with similar names.  This feels quite confusing so we have summarised the history of the regime changes.

When does it start?

This depends on whether you have reporting obligations in the European Union (EU) under ESMA, or in the United Kingdom (UK) under the FCA.

The start date for the EU is confirmed for Monday, 29 April 2024.

The start date for the UK is confirmed for Monday, 30 September 2024.

What's the biggest change?

A move from CSVs submissions to XML only

One of the global financial regulators’ goals of 
introducing ISO 20022 XML is to improve reporting quality. Where each trade repository has had its own unique submission format to date, it has caused difficulties in data sharing and matching between repositories.

By unifying the submission format to the ISO 20022 XML schema, this should eliminate the risk of discrepancies between reporting parties and repositories due to inconsistent data and allow generation of cleaner data with less variation of file formats for matching among repositories.

Are there any new fields we have to send data for?

In total there are 203 fields in the EU Refit specification.  This is a significant increase from the number of fields that are currently required to be reported.  TRAction is contacting our current clients to advise them what additional information needs to be provided and how to send it to us.  For new clients, we have an updated file specification ready to be provided so you can start preparing to transition to TRAction.

Isn't there an EMIR 3 too?

Yes, the most recent revision of the European Market Infrastructure Regulation, which governs the EU’s derivatives market, is known as
EMIR 3.  The updated regulation seeks to improve the effectiveness and resilience of the EU clearing system while addressing some of the risks and problems brought on Brexit and the energy crisis.  It will likely have little to no impact on reporting to a Trade Repository.

What is Refit and Wasn't It Done in 2017?

REFIT – “Making EU Law Simpler, Less Costly and Future Proof”

  • The European Commission’s Regulatory Fitness and performance programme (REFIT) aims to ensure that EU laws deliver on their objectives at a minimum cost for the benefit of citizens and businesses.
  • The Commission presents every year an overview of its efforts for simplification and burden reduction in the Annual Burden Survey and monitors regularly the programme’s progress in the REFIT scoreboard. A high-level group – the Fit for Future Platform – advises the Commission on how to achieve the REFIT objectives and modernise EU laws.
  • Basically it’s like Microsoft Windows updates, except a little harder to apply than just downloading, waiting 15 minutes and then restarting your computer.
  • In November 2017, we got the first EMIR Refit which added some collateral fields and country of counterparty. No one paid much notice as MiFID II was going live 2 months later.
  • Refit is broader than just EMIR and is applied to other regulations. It was launched in 2012.

Reporting with TRAction

TRAction's Integrations

If you’re considering passing the burden of reporting over to a delegated third-party, like TRAction, you’re probably wondering, “Can they connect to our current trading platform?”
Find out about TRAction’s reporting integrations to automate your daily obligations.


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UK EMIR Refit - TRAction's Suggested Implementation Timeline

29 April 2024
EU EMIR goes live

The new EU EMIR Refit rules require revised reporting began on 29 April 2024

May 2024
Source Underlying Data for Additional Fields
June 2024
Be Able To Produce an XML Output File
June 2024
Decide Whether Reports Will Be Created Manually or Automatically
December 2023
Integrate New Data With Existing Fields in New XML Format
June 2024
Choose a Trade Repository or Agent
29 January 2024
Unique Product Identifier (UPI)

The UPI service from ANNA-DSB has gone live.  TRAction is working closely with the service for its clients.

July 2024
Be Able to Ingest and Read Daily Confirmation Files in XML
August 2024
Delegated Reporting
September 2024
Perform Test XML Reports
30 September 2024
UK EMIR goes live

The new UK EMIR Refit rules require revised reporting will begin on 30 September  2024

to discuss the changes and your requirements today.