Regulatory Reporting | EMIR REFIT Transaction Reporting

What is EMIR Refit Transaction Reporting?

EMIR Refit (European Market Infrastructure Regulation Refit) is the mandatory regulatory update to the existing EMIR transaction reporting rules, which requires financial firms to report their over-the-counter (OTC) derivatives transactions in the EEA (European Economic Area).

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Former FCA regulator, Sophia Fulugunya discusses the challenges firms face with EMIR Refit Transaction Reporting requirements.

About EMIR Refit

The European Market Infrastructure Regulation (EMIR) covers derivatives, central counterparties and trade repositories and was initially adopted in 2012 with the amended version, EMIR Refit adopted later on in 2019. Following Brexit, there are now UK EMIR and EU EMIR regulations. The new rules under EMIR Refit came into effect on 29 April 2024 for EU entities and with UK entities having a later go-live date of 30 September 2024.

The publication of the new changes in 2024 supports the main purpose of EMIR to reduce systemic, counterparty and operational risk and increase transparency in the OTC derivatives market. It also aims to improve the data quality, provide clarity to firms where required and streamline the registration process for Trade Repositories (TRs).

Who will be primarily affected under 2024 EMIR Refit?

  • Counterparties in scope of the reporting requirements under EMIR Refit
  • TRs registered, or recognised, under EMIR Refit
  • Third party service providers who offer reporting services to counterparties subject to reporting under EMIR Refit

What are the changes under 2024 EMIR Refit?

  • More reporting fields: Increase in the number of reportable fields from 129 to 203. A small number of fields have been removed, such as “Trade capacity”.
  • Change in reporting format from CSV to XML: ISO20022 standard, the open global standard for financial information, requires EMIR reports to follow standardised XML structure.
  • Unique Trade Identifier (UTI): For derivatives reports concluded after the effective date, a specific UTI code will be used to update the state of these reports.
  • Unique Product Identifier (UPI): UPI will be required to report most derivatives trades and must be present in the Derivatives Service Bureau (DSB) database.

EMIR Refit 2024 Updates Timeline

7 Oct 2022

EMIR Refit technical standards published in the official journal

20 Dec 2022

ESMA publishes final reporting guidlines, validation rules and reporting instructions

24 Feb 2023

FCA publishes final reporting rules

29 April 2024

EU EMIR Refit goes live

30 Sep 2024

UK EMIR Refit goes live

Rely On Qomply To Help

Qomply has a variety of solutions to help firms comply with their regulatory EMIR Refit reporting obligations:

QomplyEngine generates EMIR REFIT transaction reports QomplyEngine - Generate Transaction Reports From Raw Data
Builds transaction reports from raw data points and save resources and hassle by offloading transaction report generation
Quality Assurance for Transaction Reports Diagnostic Auditor - Ensure Reports Are Accurate
Apply over 1,000 accuracy checks and scenarios across your Transaction Reporting in a click
QomplyDirect send reports directly to the FCA QomplyDirect - Submit Reports Directly to Regulator
Send Transaction Reports directly to the regulator bypassing the need to use an ARM thus reducing costs and improving efficiency
Outsource your EMIR REFIT Report Operations Qomply Managed Services - Delegate Your Transaction Reporting Operations to Qomply
Qomply Managed Service alleviates the burden of technical expertise but also provides peace of mind that regulatory requirements are being met in a risk-free and cost-effective manner

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