Reg 2022/1855 specifies minimum details of data to be reported to trade repositories, type of reports to use; Reg 2022/1860 formats, frequency and methods for reporting.
Reg 2022/1856 further specifies procedure for accessing details of derivatives as well as the technical and operational arrangements for their access.
Reg 2022/1858 on procedures for reconciliation of data between trade repositories and to apply by trade repository to verify compliance of the reporting counterparty.
Or submitting entity with reporting requirements and to verify completeness and correctness of data reported; also final report on guidelines for reporting under EMIR.
Validation rules, reconciliation tolerances and template for the notification of errors and omissions in reporting plus XML EMIR reporting schemas.
Addressees
Cyprus investment firms; UCITS and, where relevant, their management companies.
AIFs set/managed in Cyprus, where relevant their AIFMs, non-financial counterparties.
Key Aspects
Reporting under ISO 20022 XML data formats are required for communication between trade repositories (TRs) and entities and from TRs to authorities.
As for content of the reports, many amendments are introduced and detailed in depth.
Including requirements around Unique Trade Identifier (UTI), verification of completeness and correctness of data reported and inter-TR reconciliation, etc.
Required Action
Counterparties to derivatives or ERRs, where applicable, should review implications of the new rules and take the necessary action in order to ensure compliance with EMIR.
Advised to evaluate new rules impact, revise their reporting procedures accordingly.
Ensure their reports fulfil conditions of article 1 of Reg 2022/1858 to avoid rejections.
That authorization of report submitting entities confirmed pre-reporting to avoid same.
Ensure all fields, relevant to derivative reported, populated, irrespective of whether said fields noted as optional in ESMA Validation Rules; plus a few other suggestions.
Transition
From Apr. 29, 2024, all reports submitted to TRs should comply with the new rules.
Outstanding derivatives i.e. derivatives reported before that day, not terminated by it, will need to be updated to new reporting requirements no later than 180 calendar days from reporting start date (with few exceptions).
