The EMIR Refit, implemented on April 29, 2024, has ushered in significant changes to transaction reporting standards across the EU financial landscape.
According to Novatus, the EMIR Refit introduces an expanded set of reportable fields, harmonized messaging formats, and clearer guidelines from regulators on data quality expectations. Regulators have emphasized the importance of complete and accurate reporting from day one, as outlined in the Official Journal of the European Union.
According to the preamble of the EMIR Refit, accurate derivatives reporting is crucial for monitoring exposure concentration and systemic risk. Reconciliation failures indicate potential data quality issues, underscoring the need for thorough reporting and error resolution mechanisms.
In practical terms, buy-side participants and their management companies can no longer delegate EMIR reporting obligations to sell-side counterparts. They must actively monitor reporting, address issues promptly, and engage regulators with remediation plans when necessary.
Trade repositories now face increased scrutiny on data quality and consistency, with more stringent submission validations. Firms must redouble efforts to ensure accuracy, completeness, and timeliness in their reporting, fostering improved industry dialogue for error resolution.
Despite efforts, the EMIR Refit implementation has faced challenges. Pre-go-live testing posed significant time constraints, while unstable testing environments and evolving reporting requirements led to last-minute changes and retesting.
Tech issues and submission challenges further impeded data submission to repositories, prolonging the resolution of implementation hurdles. Regulators, such as the CSSF, emphasize ongoing vigilance on data quality, indicating sustained scrutiny post-Refit.
In conclusion, navigating EMIR Refit demands concerted efforts to address data quality challenges and enhance cross-industry collaboration for effective compliance. Market sentiment suggests a prolonged period of adjustment, underscoring the importance of sustained diligence in regulatory compliance.
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