At a Glance

A review of EMIR took place, referred to as EMIR Refit, with the purpose of proposing measures to reduce disproportionate compliance costs, transparency issues and insufficient access to clearing counterparties.

The European Commission (“EC”) published the Regulatory Technical Standards (“RTS”) and Implementing Technical Standards (“ITS”) in the Official Journal of the European Union on 7 October 2022, which form the revised transaction reporting standards (“EU EMIR Refit”). EU EMIR Refit RTS and ITS entered into effect on the twentieth day following their publication, triggering an 18-month implementation period. The compliance date for the changes is 29 April 2024, at which point firms are required to report under the new EU EMIR Refit technical standards.

The UK Financial Conduct Authority (“FCA”) and the Bank of England (“BoE”) published a joint policy statement on 24 February 2023 setting out the final amendments to Technical Standards in relation to the revised reporting requirements (“UK EMIR Refit”). The compliance date for the changes is 30 September 2024, at which point firms are required to report under the new UK EMIR Refit technical standards.

EMIR Refit aims to bring greater transparency to the derivatives markets through the adoption of standardised data requirements and increased alignment across global regimes and jurisdictions. Some of the key changes in the new EMIR Refit are related to the topics outlined below. 

Further detail on these topics can be found in the corresponding sections below:

1. ISO20022 XML Reporting
2. Unique Product Identifier (“UPI”)
3. Sharing attributes, including:
   1. Unique Transaction Identifier (“UTI “)
   2. Custom Basket Code
   3. Report Tracking Number (“RTN“)
4. Revised Reporting Lifecycle Events
5. Reporting obligation of significant reporting issues to National Competent Authorities (“NCAs”)
6. Changes to reportable fields