EMIR Refit implementation: Practical advice and considerations for trade reporting obligations

EMIR (European Market Infrastructure Regulation) trade reporting is a fundamental regulatory requirement for firms trading derivatives within the EU and UK. Introduced in 2014, EMIR mandates the reporting of derivative trades to authorised trade repositories to enhance market transparency and enable regulatory oversight. The recent EMIR Refit introduces new complexities, requiring firms to navigate the increased number of data fields, new XML reporting formats and different implementation dates between the EU and UK. This paper addresses three primary challenges of EMIR Refit: oversight and control of trade reporting, delegated reporting to brokers and third parties and updating legacy EMIR trades. This paper discusses the necessity for robust daily controls, governance structures and accurate data reconciliation to ensure compliance and mitigate risks. Firms must adapt to dual reporting obligations due to divergent implementation dates, maintaining separate systems for EU and UK reporting standards. Delegated reporting, while operationally beneficial, requires vigilant oversight to ensure third party compliance with regulatory standards. Updating legacy EMIR trades to align with EMIR Refit standards is crucial to maintaining data integrity and regulatory compliance. This paper provides practical guidance for firms to enhance their trade reporting processes, ensuring adherence to EMIR Refit requirements and safeguarding market stability. Through proactive planning and robust controls, firms can effectively manage the challenges posed by EMIR Refit, maintaining compliance and operational efficiency in the evolving regulatory landscape.