Following a protracted consultation process, each of the EU and the UK has now finalised its revised requirements for trade reporting under the European Markets Infrastructure Regulation ("EMIR") following the revision of EMIR in 2019 ("EMIR Refit").
Who needs to read this briefing?
All EU or UK users of derivatives will be impacted by these new trade reporting requirements.
What do I need to do now?
Derivatives users will need to address certain operational changes to ensure that they have the correct systems and processes in place, either directly (where they report to a trade repository) or indirectly (by seeking confirmation from their counterparties or reporting delegates that the necessary changes have, or will be, made).
What is the timeline for implementation?
The new trade reporting rules are subject to a transitional period for implementation that will come to an end for EU counterparties on 29 April 2024 and UK counterparties on 30 September 2024.