EMIR Trade Reporting changes - The revised RTS/ITS
EMIR trade reporting is going to go through some fundamental changes in 2017. ESMA are introducing a large addition of new fields, changes to position reporting, collateral reporting and asset class specific fields. These EMIR trade reporting changes are far more complex and onerous than the Level 1 and Level 2 validation changes – if you are not already planning for these changes, you need to start now.
- Additional values for spreadbet and swaption in the interim taxonomy
- Whole of the Aii code needs to be populated rather than just the Exchange Product Code
- ‘Corporate Sector’ extended to NFCs (NonFinancial Counterparties)
- Legal text changed to ensure UTI shall be communicated to the other counterparty in a timely manner by the generating one so that it can meet its reporting obligation (CCPs to generate UTI with clearing member; clearing member generate for client)
- Additional asset class specific fields for CDS
- Increase in number of interest rate specific fields
- Clarification on how to populate notional amount by derivative type
- Complex derivatives to be decomposed for reporting and linked with new ‘Complex Trade Component ID’
When are the changes being implemented?
At time of writing, ESMA has not confirmed the exact start date, but it is expected to be implemented in Q3 2017.
Why is this happening?
Due to time constraints, the EMIR trade reporting requirements weren’t quite as perfect as they might have been. As a result, the new reporting RTS* and ITS** are designed to:
- Clarify data fields, their description or both;
- Adapt existing fields to the reporting logic prescribed in existing Q&As or to reflect specific ways of populating them;
- Introduce new fields and values to reflect market practice or other necessary
- Align EMIR standards with MiFIR transaction reporting