EMIR Reporting
Simplified

We’ve identified the most common errors (for both EU and UK) in the data we receive from our clients:

1. Original Not Found
2. Invalid Lifecycle Transition
3. ‘Valuation timestamp’
4. ‘Country of the counterparty 2’ field populated with
5. invalid country code
6. UTI reused for a new trade
   Invalid LEI used

Read more.

As a delegated reporting service provider, TRAction is asked a lot of questions regarding EMIR, MiFIR and SFTR requirements. 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.

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.

We all know that meeting all the requisite trade/transaction reporting obligations for EMIR, MiFID 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.

There are a number of regimes including EMIR, MiFID II/MiFIR, SFTR and Best Execution, all of which affect Investment Firms (IFs) in different ways. Read more to see the regulatory reporting required by IFs.

While trade and transaction reporting rules allow firms to delegate their 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.

There are certain fields within the regimes of EMIR, MiFIR, SFTR, ASIC, MAS and Canada, which require populating with an LEI.

Check out our article, where we detail regimes and LEI fields for population and validation.

Read more.

A commonly asked question by many trade reporting entities is what value to use when the underlier to the relevant instrument has no ISIN under EMIR. (An ISIN is an international securities identification number which is a product identifier code often required by trade reporting regimes).

Where no ISIN is available for equity trades or for the identifier of the relevant derivative’s basket’s constituents, then ESMA’s stated best practice is to use the ISIN for the European Financial Stability Facility. We discuss how to populate the ISIN in detail in this article. Click here to read more, or check out our insightful video here.

ESMA has released its Report on Quality and Use of Data (Report) for 2024 which looked into data reported under regulations that are within EMSA’s remit.

Although the Report covers data reported under EMIR, MiFIR and SFTR, there is emphasis on the outcomes of EMIR Refit since its implementation in April 2024 which impacted a large number of reporting counterparties and trade repositories.

The Report also contains an overview of sanctions imposed by the National Competent Authorities (NCAs) on reporting obligations (which has not been considered in ESMA’s previous data reports). Click here to read more.

Since the EU & UK EMIR Refit trade reporting regime updates in April and September 2024, many firms have been asking how to deal with the backloading of collateral and valuation information.

In this article, we unpack:

• ESMA and FCA guidance on backloading requirements
• When to use the ‘Margin update’ vs ‘Correct’ action types
• How to ensure accuracy across historic valuation and collateral reports
  
  

Click here to see more.

Since the EMIR Refit updates in 2024, many firms have faced challenges creating and maintaining consistent client identifiers for 'Counterparty 2' clients.

Reasons for duplication and reconciliation issues include:

• Confusing platforms' login IDs with EMIR client codes
• Different IDs for the same person across platforms
  
  

Click here to read our article, which breaks down the  requirements, how to structure Unique Client IDs, and how TRAction helps firms link their client records correctly.

One year on from the final phase of EMIR Refit go-live (EU April 2024, UK September 2024), the derivatives industry seems to have settled after the changes, but not without some surprises.

The switch from CSV to XML proved to be smoother than expected. However, there are still issues with UPIs, lifecycle event errors and pairing and matching, which appeared to cause TRs some teething issues.

In our article, we discuss:

• The reduction in error rates post Refit
• The role of service providers
• ESMA's call for evidence on dual-sided reporting
  
  

Click here to read more.

The FCA has shared its observations on the industry's performance post-Refit.

Key takeaways:

• Errors & Omissions: If in doubt, submit a breach notification. The FCA advises firms to err on the side of caution.
• Change management: resource planning and early engagement are critical during regulatory transitions.
• The FCA advises firms to have suitable systems and controls in place for compliance
• While 95% of reports were successfully converted and resubmitted by the end of the 6-month transition period, some persistent issues remain.
  
  

Click here to read more.