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Under the European Market Infrastructure Regulation (EMIR), all counterparties are required to report details of any derivative contract they have concluded, or which the counterparty has modified or terminated.

EMIR reporting requires:

  • the reporting of OTC derivatives;
  • the clearing of eligible OTC derivatives;
  • measures in place to reduce counterparty credit risk and operational risk for bilaterally cleared OTC derivatives;
  • common rules for central counterparties (CCPs) and for Trade Repositories (TRs); and
  • rules on the establishment of interoperability between CCPs.

EMIR Reportability Assessment Tool

Are you unsure if you have EMIR reporting obligations? Or maybe, you’re not certain on which specific requirements apply to you? TRAction has developed an assessment tool to help you determine your EMIR reportability.

Reporting obligation

EMIR requires all market participants to report details of all derivative contracts (interest rate swaps, FX, credit, equity and commodity) to TRs.

Both counterparties must report each trade unless:

Where one counterparty reports on behalf of another counterparty, or a third-party reports a contract on behalf of one or both counterparties, the report details will include the full set of details as required by each counterparty.

Collateral reporting

Different from MiFIR reporting, EMIR requires any collateral transferred, between two counterparties to a transaction, to be reported in EMIR Trade Reports. Collateral can be reported on 2 bases and also broken down into 3 types. Click here to see detailed information with examples to help you understand.

Who does EMIR apply to?

EMIR applies to any entity established in the European Union (EU) that has entered into a derivative contract, and applies indirectly to non-EU counterparties trading with EU parties. EMIR recognises two (2) main counterparties to a derivatives contract:

  • Financial counterparties – investment firms, fund managers, banks, insurers etc.
  • Non-Financial counterparties – entities not involved in financial services.

What needs to be reported and to whom?

Financial and non-financial firms trading in derivatives must report details of all derivatives trades via a TR. This includes all the details of trades and any event thereafter that affects the valuation or the terms of the trade.  It also includes identification of the country of the counterparty (country of incorporation for legal entities, country of residence for natural persons).  EMIR covers OTC derivatives and exchange-traded derivatives.

Any derivative contract is required to be reported under EMIR reporting requirements, and includes:

  • Financial derivatives settled physically or in cash;
  • Commodity derivatives that must or may be cash settled
  • Physically settled commodity derivatives that are traded on a regulated market
  • Physically settled commodity derivatives that have characteristics of other derivative financial instruments

The definition of a derivative contract is based on the Markets in Financial Instruments Directive (MiFID).

When do reports have to be made?

Reports are required to be submitted to a registered TR no later than one working day after the trade has been made (T+1).

What is the revised EMIR RTS and ITS?

In November 2017, the revised Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) began to apply. The changes made by the RTS and ITS to EMIR include addition of reportable instrument classes, increase in the number of reporting fields, changes to collateral reporting and introduction of the requirement to report CFI codes.

What are the different reporting methods?

You are required to report all details of a derivative contract as well as any modification or termination of the contract. Depending on how our client’s system works, TRAction has 3 different reporting methods ready to be tailored to our clients’ needs.

9 common mistakes

We’ve identified 9 of the most common mistakes that investment firms make in their EMIR reporting. Find out what these mistakes are and get it right from the start with our simple tips.

Delegated Reporting – How can we help you?

TRAction can provide you with delegated reporting solutions in accordance with the reporting requirements outlined above. We assist with understanding your EMIR trade reporting obligations and simplify your reporting process. If you want to find out more about our services, please contact us. Wondering about how much we charge? See our pricing schedules here.

Reporting Quality Checks

Our clients can also conduct regular check of our service quality. Visit our Regular Quality Checks page to find out how you can be assured that we are doing a great job for you.

EMIR Refit

Introduced on 17 June 2019, EMIR Refit intends to streamline the existing reporting obligations in order to improve the quality of the data reported, make supervision more effective and increase access to clearing by removing existing unnecessary obstacles. EMIR Refit requires Financial Counterparties and Non-Financial Counterparties that are not subject to the clearing to report their OTC derivative contracts. View our EMIR Refit page to determine your reporting obligations under this regime.

Transitioning to new EMIR & MiFIR Reporting

Thinking of changing your current regulatory reporting service? Transitioning to a new regulatory reporting service can seem daunting. We understand the stress clients may face when switching to another TR, ARM or reporting delegate.

TRAction is here to make this process as easy as possible for you. We’ve worked extensively with other TRs and ARMs. Whether you are transitioning between TRs/ARMs or just looking to switch your reporting delegate, TRAction will ensure it is a smooth process and will help you manage the transition without hassle. Find out why you should make the transition to TRAction.

Firms that use TRAction for their EMIR reporting find they save time and money in complying with their regulatory requirements. We would be happy to talk to you about how we can help to simplify your EMIR reporting requirements, contact us on +44 20 8050 1317 in the UK or +61 2 8960 7248 in Australia.

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Further Information

Understanding your reporting obligations and determining whether a third party reporting solution will save you costs and internal resources are important steps towards compliance with your trade and transaction reporting requirements. Choosing a strategic approach to compliance will give you a competitive advantage and ensure you avoid penalties for non-compliance. To make things easy, we’ve created the Ultimate Guide to Transaction Reporting in Europe. Read more.

TRAction has outlined the key differences between EMIR and MiFIR. Our team has also pointed out some of the issues that investment firms need to be aware of under EMIR and MiFIR, so that you can stay compliant with the trade/transaction reporting requirements. Read more.

As a delegated reporting service provider, TRAction is asked a lot of questions regarding EMIRMiFIR and SFTR reporting. That’s why our team has put together some of our most frequently asked questions, so that you can learn how to seamlessly report transactions under multiple regimes. Read more.

We’ve identified the 3 most common errors in the data we receive from our clients:

  1. NonReportingPartyCountry field populated with invalid country code
  2. UTI reused for a new trade
  3. Invalid LEI used

Read more.

ESMA asks for any collateral transferred, between two counterparties to a transaction, to be reported in EMIR Trade Reports. Collateral can be reported on a per position basis or on a portfolio basis. Read more.

While EMIR and MiFIR trade and transaction reporting rules allow reporting entities to delegate their reporting obligations to a third party, they remain ultimately responsible for ensuring the details of their transactions are reported correctly and accurately under Art 9(1) of EMIR & Art 26(7) of MiFIR. Read more.

Each Investment Firm (IF) is required to make a quarterly assessment on its previous 6 months’ data to determine if it qualifies as a Systematic Internaliser (SI). Where an IF is classified as a SI, it will be obliged to meet the pre- and post-trade transparency requirements. Read more.

We all know that meeting all the requisite trade/transaction reporting obligations for EMIRMiFID II/MiFIR and SFTR can pose a considerable cost to an investment firm. While the regulatory burden is not going to disappear, it can be minimised by outsourcing and choosing the most cost-effective and efficient option for you. Read more.