Are you ready?
Do you have the right compliant data?
The new regulations mean that firms will face significant changes to the data that is currently reported, in addition to multiple new fields that will need to be submitted for the first time. Given the operational changes that firms will need to consider in order to produce these reports, it is vitally important to factor in enough time to ensure that you have the right data and is 'ready' for go live.
These are the key considerations firms should have in mind:
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More reportable fieldsincluding upto 90 new fields, removal of 15 fields, and updates to the name, definition, and format of how to report a field. Note: This is more than double MiFIR’s reporting obligations. -
XML formatAn ISO200022 global messaging standard, requiring you to adopt a standardised XML structure, rather than the more common and popular csv format used today by the vast majority of ‘reportees’.
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Reportable counterpartiesEU EMIR applies to all entities established in UK that enter into, modify, or terminate a derivative transaction. In most cases, both counterparties (the ‘buyer’ and the ‘seller’) must file a report for each trade.
EU firms have a 6-month transition period (29 April to 26 October). This time is given to firms to prepare and perform the first Refit-compliant ‘full load’. (Note: changes in outstanding derivatives after go-live must be reported to the new standard).
It is also important to note that in the five month interregnum between EU and UK EMIR Refit regulatory deadlines, reporting entities that report currently in both jurisdictions will have to report UK EMIR under the ‘old rules’ and EU EMIR under the new ones.
Getting the right data in the right boxes at the right time is the most pressing challenge.
At FOW, we specialise in guiding firms through such regulatory complexities, ensuring a seamless transition to EMIR Refit compliance. Whether you're already operational or in the planning stages, we are here to ensure you have the right data in the right place at the right time.
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Not only is there a requirement to report additional information, EMIR Refit also places enormous emphasis on enhancing and harmonising the quality of the data itself to support end to end validation and data reconciliation obligations, and to mitigate the risk of misreporting - and having to report associated reporting failures.
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Speaking at the FOW Trading Amsterdam conference on Wednesday, Niels Lemmers, head of Public Affairs at Flow Traders, said the so-called EMIR 3.0 regulation fails to tackle the main European problem -
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Wrongly ‘labelled’ products and the wrong information in the wrong reporting fields will cause EMIR Refit reporting failures, with associated tedious and costly remediation and re-reporting and potential for regulatory penalties and sanctions.
