In this paper, Capco provides industry insights to the imminent changes due to impact EMIR reporting under the new technical standards, for the reporting of OTC Derivatives under Regulation (EU) 2019/834 (EMIR REFIT), as well as the key challenges and considerations for investment firms in preparation.

The benefit of mandatory delegated reporting may in the end be minimal due to the on-going need for smaller firms to report exchange-based activity and provide the required data to the reporting firm. However, it is a welcome step.

The EMIR REFIT standards are likely to require material work to implement and the response by ESMA regarding use of ISO20022 standards and Critical Data Element Methodology will be key.

Firms should start to consider their approach to implementation (across data, technology, people, and processing) from Q1 2021 given this requirement will be due in Q3 2022.

For more information about this report, or our regulatory practice, please contact Tej Patel, Partner.