Get your UK EMIR backloading done before 30 September 2024
UK EMIR Refit comes into effect on 30 September 2024. TRAction recommends that reporting entities should do any UK EMIR backloading before this date, otherwise they may have trouble getting old data to meet the UK EMIR Refit format.
- UTI – UK EMIR Refit adopts the UTI standards as promoted by CPMI-IOSCO. Bilateral agreements are considered fallbacks and where there is no agreement in place, firms are to follow the UTI waterfall for UTI generation. Entities should review the format of UTIs of existing transactions and ensure they:
- consist solely of alphanumeric characters; and
- are composed of a combination of the LEI of the generating entity and a unique code created by that entity, totaling 52 characters.
- consist solely of alphanumeric characters; and
Entities should also determine the approach to be taken before 30 September 2024 to the generation and matching of UTIs. If firms require bilateral agreements in place on UTI generation with their counterparties, to try and resolve this well before 30 September 2024.
- UPI – The FCA has specified in its Standards Instrument (Article 7 of Annex B) that:
- derivatives which are admitted to trading or traded on a trading venue or a systematic internaliser should be using an ISIN.
- Remaining derivatives should be identified using a UPI.
- derivatives which are admitted to trading or traded on a trading venue or a systematic internaliser should be using an ISIN.
This means entities should ascertain which of these 2 categories their transactions fall under. If they fall under the ‘remaining derivatives’ category, UPIs will need to be obtained for those trades.
- Counterparty 2 industry – There may be instances where some entities have not transacted with a particular counterparty for a few years and have no information relating to their industry or sector. Searches can be performed or queries with counterparties can take place prior to 30 September 2024 to obtain this information.
Summary
If you are aware of any historical inaccuracies in your trade reporting that you plan to correct with a backload, we strongly advise that you complete this backload project before 30 September 2024 so you don’t have to meet the new UK EMIR Refit standards and validations.
Please see our earlier articles for more information on UK EMIR Refit.
If you have any concerns or questions on how the UK EMIR Refit will affect your business operations or how to start backloading, please get in touch with us.
