After several rounds of consultation with market participants and industry groups and a lengthy legislative process, the final version of EMIR Refit was published in the Official Journal of the European Union on October 7, 2022. Considering the 18-month implementation period, the new regulations will apply from April 29, 2024.
EMIR has been around for over a decade since its initial adoption by the EU legislature in mid-2012 until the present day. During this time, it has undergone multiple changes in the form of both smaller ESMA revisions and larger changes such as the Review of Technical Standards in 2017. The aim of each change was to address the low data quality levels and to harmonize across regimes. The previous changes are however incomparable in scale to the EMIR Refit review of Technical Standards.
The EMIR Refit publication defines precise standards for reporting, registration of Trade Repositories, data quality, reconciliation, and validation – all elements that will have broad and significant impacts on submission procedures.
Firms should keep in mind several key items when preparing for the EMIR Refit:
- Increased number of reporting fields from 129 to 203 where most existing fields will change, often significantly
- Introduction of event types on top of action types, resulting in 34 action/event type scenarios
- Mandatory use of the ISO 20022 XML format for reporting, including reports generated by the Trade Repositories
- Introduction of Unique Product Identifier (UPI) which is designed to facilitate effective aggregation of OTC derivatives transaction reports on a global basis
- Extended list of reconciliation fields with stricter requirements for matching
Moreover, after April 29, 2024 companies will have six months to complete the update of outstanding trades into Refit.
The time before the EMIR Refit go-live should be used wisely by all reporting participants under EMIR to prepare for this significant change in reporting requirements.
SimCorp enables customers to automate EMIR Refit regulatory reporting obligations and processes leading to complete, accurate, and timely reporting through a single vendor. In the SimCorp Regulatory Reporting Team, we have closely followed the developments around the EMIR Refit and have analyzed all related materials released by ESMA. Our team of experts can help you understand the impact of these modifications and how to prepare for the significant challenges ahead.
If you are interested in hearing more about our reporting services to help you stay compliant with regulatory requirements, please contact us at [email protected].