EMIR Refit 2024
Until EU Refit
Monday, 29 April 2024
Until UK Refit
Monday, 30 September 2024
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.
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Refit By Numbers
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.
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, 24 April 2024.
The start date for the UK is confirmed for Monday, 30 September 2024.
A move from CVS submissions to XML only
One of 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.
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.
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 by Brexit and the energy crisis. It will likely have little to no impact on reporting to a Trade Repository.
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