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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. Due to Brexit, the EU regulations have been onshored as UK EMIR under the European Union (Withdrawal) Act 2018. On this page, EMIR refers to both EU and UK EMIR unless otherwise specified.

EMIR reporting requirements involve:

  • reporting all derivative contracts – both over-the-counter (OTC) and exchange-traded;
  • clearing eligible OTC derivatives;
  • measures 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.

Who has an EMIR reporting obligation?

EMIR requires all counterparties and CCPs to report details of any derivative contract (with the underlying asset classes – interest rate, FX, credit, equities and commodities) they have concluded and of any modification or termination to TRs.

EMIR recognises 2 types of counterparties to a derivative contract:

  • Financial Counterparties (FC) – investment firms, fund managers, banks, insurers etc.; and
  • Non-Financial Counterparties (NFC) – entities not qualified as a financial counterparty, including those not involved in financial services.

Each counterparty must report their leg of a trade unless:

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

What to report and to whom?

Financial Counterparties (FC) and Non-Financial Counterparties (NFC) 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).

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; and
  • physically settled commodity derivatives that have characteristics of other derivative financial instruments.

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).

How can we help you?

TRAction can provide you with delegated reporting solutions in accordance with the reporting requirements outlined above. We help you understand your EMIR trade reporting obligations and completely simplify your reporting process. Depending on how our client’s system works, TRAction has 3 different reporting methods ready to be tailored to our clients’ needs.

If you want to learn about our services, please get in touch with us.

Wondering how much we charge? View our pricing schedules.

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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.

Natural person identifiers are an important part of transaction reporting and contain some complexity in their application due to the variety of identifiers available. 

It’s widely-known that corporate counterparties need to be identified by their legal entity identifier (LEI) in MiFIR transaction reports. This is simple and straight-forward.

Where the counterparties are natural person, the reporting of natural person information including identifiers, names and dates of birth will be required. The type of identifier to be used will depend on the priority given in the Annex II of RTS 22. Read more.

Want to know why over 400 firms report their trades through TRAction?

Contact us to simplify your trade and transaction reporting.