With the compliance date now set on 29 April 2024, counterparties will need to report under the new standards, including upgrading outstanding derivatives to the new reporting standards.
Some of the key differences that the EMIR Refit package brings are:
- New ISO 20022 XML Data Format.
- Unique Product Identifier (UPI) to be used where an ISIN is unavailable.
- Position-level reporting will be selected over transaction level where the conditionalities of the RTS/ITS are met.
- Additional details and values to be included in the report regarding, collateralisation, the reporting of corporate events and the direction of the transaction etc.
- New data points, for example, Post Trade Risk Reduction (PTRR), events (e.g., Compression), identifiers for crypto derivatives, additional points on asset characteristics, information on delta values etc.
- Delegated Reporting – Report Submitting Entity (RSE) must provide the Entity Responsible for Reporting (ERR) with transparency to the records reported on their behalf, and to any data quality issues encountered.
- Introduction of an Errors and Omissions notification to NCAs.
- A new provision by ESMA, that would require the counterparties to have in place written internal procedures to resolve any reconciliation break identified by the Trade Repositories (TRs).
- Increase in the number of reconcilable fields to be reconciled from the date when the new RTS/ITS package begins to apply with several more fields becoming reconcilable 2 years after the go-live date.
|Valuation becomes a reconcilable field. This means that where 2 EEA counterparties to a derivative contract respectively mark-to-market the valuation amount of said contract, if those values are outside tolerance level, this field will not reconcile, and the transaction will not be matched.|
|Trade Repositories in case of a paired report between 2 EEA counterparties that have not been reconciled (matched, field by field) will stop attempting to reconcile the derivative 30 calendar days after the derivative ceases to be outstanding.|
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