Last call: EMIR Refit

We are only five months away of the European Union EMIR Refit go-live date which is set to April 29, 2024, and it is less than a year for United Kingdom EMIR Refit where the application of the new requirements will become mandatory from September 30, 2024. The complex reporting logic as well as ISO20022 XML reporting format will have to be implemented by the market participants by that time.

How we make sure our clients are ready for the go-live date

When it comes to EMIR Refit, it has been quite a long journey for SimCorp to prepare for this biggest change in the EMIR regulation so far. In the Regulatory Center of Excellence, we have closely followed the developments around EMIR Refit and analyzed all related materials released by ESMA and FCA, including the consultations on RTS and ITS as well as on the guidelines for reporting. We want to make sure that all our clients are ready for the go-live date and with that objective in mind, we formed a dedicated team to focus on making our reporting solution adherent to the updated regulation. We built the solution, which covers the new EMIR Refit specifications and properly addresses the increased complexity of the new requirements. Due to its architecture, we are taking ownership of maintaining connectivity to Trade Repositories.

We spent a few months on extensive testing using available Trade Repositories UAT environments and simulators to make sure that the solution meets the highest standards. We supported our clients with a data requirements assessment and indicated areas on which they should concentrate during the preparation process.

Moreover, we already started working with our clients on EMIR Refit solution implementation in their environments to make sure they will have enough time for testing.

SimCorp also support clients in UPI sourcing and storing data in SimCorp Dimension. We introduced dedicated UPI fields in Trade Manager and APL window. Additionally, SimCorp offers a dedicated ANNA DSB UPI interface service, providing a standardized pre-configuration to seamlessly integrate ANNA DSB Unique Product Identifier data into SimCorp static data. The integration into SimCorp Dimension provides our clients with a quick and easy method of sourcing and saving UPI in a dedicated field.

In preparation to EMIR Refit, you should acknowledge that UPI values will be required not only for new contracts traded after April 29, 2024 but also for all open transactions that need to be backloaded within six months of the EMIR Refit go-live date.

Testing is the most important phase to ensure successful delivery of regulatory reporting projects

The first quarter of 2024 will be very busy for all market participants who are preparing to EU EMIR Refit reporting start date. This is the time when you should make sure that all new data required after April 29, 2024 are already in the sourcing system. However, this is also the time which you should mainly spent on testing of the end-to-end reporting. Testing is the most important phase to ensure successful delivery of regulatory reporting projects. Proper testing will enable you to discover issues in your reporting and mitigate risk of incorrect reporting ahead of the go-live date. As a preparation you should think about testing scenarios which will capture your different activities and products. It’s a also a good idea to include into the testing phase production parallel testing which can help identify issues that you did not necessarily flag in your testing scenario base.

We can help you understand the impact of EMIR Refit

The deadline for EMIR Refit compliance is fast approaching, and for a significant number of firms affected, there's still a lot to get done. Given the complexity of the regulation and possible hurdles firms may encounter in the process, firms should be well underway with their EMIR Refit implementation. Challenges with the scale of the change, potential unexpected technological issues and the dual implementation deadline means that the risk of non-delivery is high. SimCorp’s team of experts can help you understand the impact of EMIR Refit and how to prepare for the significant challenges ahead. SimCorp enables customers to automate EMIR Refit regulatory reporting obligations and processes leading to complete, accurate, and timely reporting through a single vendor. SimCorp Regulatory Center of Excellence helps you stay compliant with the ever-changing regulatory requirements. We take more responsibility for keeping the reporting solution updated in your environment, so you use fewer resources on maintaining and operating reporting solutions. This is the final call to start working on EMIR Refit preparation.