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EMIR Refit implementation: Practical advice and considerations for trade reporting obligations
Journal of Financial Compliance,
8
(2),
144-153
(2024)
Abstract
EMIR (European Market Infrastructure Regulation) trade reporting is a fundamental regulatory requirement for firms trading derivatives within the EU and UK. Introduced in 2014, EMIR mandates the reporting of derivative trades to authorised trade repositories to enhance market transparency and enable regulatory oversight. The recent EMIR Refit introduces new complexities, requiring firms to navigate the increased number of data fields, new XML reporting formats and different implementation dates between the EU and UK. This paper addresses three primary challenges of EMIR Refit: oversight and control of trade reporting, delegated reporting to brokers and third parties and updating legacy EMIR trades. This paper discusses the necessity for robust daily controls, governance structures and accurate data reconciliation to ensure compliance and mitigate risks. Firms must adapt to dual reporting obligations due to divergent implementation dates, maintaining separate systems for EU and UK reporting standards. Delegated reporting, while operationally beneficial, requires vigilant oversight to ensure third party compliance with regulatory standards. Updating legacy EMIR trades to align with EMIR Refit standards is crucial to maintaining data integrity and regulatory compliance. This paper provides practical guidance for firms to enhance their trade reporting processes, ensuring adherence to EMIR Refit requirements and safeguarding market stability. Through proactive planning and robust controls, firms can effectively manage the challenges posed by EMIR Refit, maintaining compliance and operational efficiency in the evolving regulatory landscape.
Keywords: EMIR Refit UK; EMIR Refit go live; EMIR compliance; EMIR FCA guidelines; EMIR Refit implementation; EMIR Refit schema; EMIR reporting xml conversion; EMIR Refit changes; EMIR regulatory updates; EMIR impact
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Author's Biography
Nik Volpe is the founder of Laurellis Associates, an independent consultancy recognised for its expertise in regulatory change, compliance and operational risk management within the financial services industry. Leveraging an insightful understanding of regulatory operations and compliance, Nik delivers tailored strategic and tactical solutions that mitigate compliance risk, enhance operational efficiency and seamlessly integrate regulatory requirements into daily business activities. Nik's comprehensive regulatory knowledge, combined with a keen insight into risk management, positions him as a trusted adviser to firms navigating the complexities of financial regulations. His approach not only minimises compliance risk but also fosters value creation and efficiency within clients' operating models. Nik holds a BSc degree in physics from Imperial College, London, which underpins his analytical and methodical approach to problem solving. Through Laurellis Associates, Nik is committed to driving transformative change and ensuring that firms remain resilient and compliant in an ever-evolving regulatory landscape.
Avinash Shamdasani is the Global Head of Trade and Transaction Reporting at BGC Group, where he leads the regulatory reporting operations and quality assurance teams. With an extensive portfolio that spans critical regulations such as the Markets in Financial Instruments Regulation, European Market Infrastructure Regulation and Securities Financing Transaction Regulation, Avinash ensures that the firm's compliance framework meets the highest standards. Avinash's career in the regulatory space includes pivotal roles at Bloomberg, UniCredit, Morgan Stanley and Citi, where he has consistently driven excellence in regulatory reporting and compliance. His academic credentials include a master of science in business and management and a master of business administration (MBA) from the University of Strathclyde. His MBA thesis, titled ‘Potential Challenges faced by Investment Firms in Meeting Enhanced Transaction Reporting Obligations under the Markets in Financial Instruments Directive II (MiFID II’, underscores his deep expertise in navigating complex regulatory landscapes. Additionally, Avinash holds a bachelor of commerce and a diploma in systems management, further solidifying his comprehensive understanding of both business and technical aspects of regulatory compliance. Known for his strategic vision and meticulous approach, Avinash is dedicated to delivering robust regulatory solutions and driving transformational change within the financial services industry.
Kalyan Deshpande is the founder of Reg-X Innovations, a leading regulatory technology, consulting and outsourcing firm. Reg-X leverages cutting-edge technology to deliver exceptional value, providing platforms for regulatory reporting and oversight, records keeping and periodic reporting, which are extensively utilised across the industry. With two decades of experience in regulatory reporting, compliance and technology, Kalyan has worked with prestigious financial institutions including LGIM, Schroders, Nomura, LBG and Barclays. He has adeptly managed and successfully delivered large-scale programmes involving regulatory implementations, remediations and back-reporting. Kalyan possesses in-depth knowledge of capital markets regulations such as the Markets in Financial Instruments Directive II, Markets in Financial Instruments Regulation, Securities Financing Transaction Regulation and Alternative Investment Fund Managers Directive. His consultancy expertise has benefited clients at renowned firms such as PwC, Delta Capita and Alpha FMC. Furthermore, he has worked closely with senior stakeholders, industry associations and trade bodies, including the Investment Association and the International Capital Market Association. Kalyan's academic credentials are equally impressive. He holds a master's degree in computer applications from VJTI, one of India's most esteemed engineering institutions. He also earned a bachelor's degree in science with specialisation in computer science. Additionally, he has completed CFA Level I and has been honoured by the Centre for Development of Advanced Computing in India. Kalyan's comprehensive understanding of regulatory environments, combined with his technical acumen and strategic insight, has positioned him as a sought-after expert in the financial services sector. His commitment to excellence and innovation continues to drive Reg-X Innovations towards new heights of success and industry leadership.
