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EMIR Reporting Industry Best Practices Matrix February 2020
EMIR Reporting Industry Best Practices Matrix February 2020
This document does not constitute legal, regulatory, accounting, tax or financial advice.
It reflects feedback received by ISDA, FIA, IA, GFXD, EFAMA, BVI and/or EVIA from swap
market participants (including both dealer and buy-side firms) who, as members of one
or more of the participating trade associations, participated in the Working Groups,
committees and member forums and it is not meant to be binding in any way. As with
all guidance and market information that ISDA, FIA, IA, GFXD, EFAMA, BVI and/or EVIA
disseminates, parties are free to choose alternate means of addressing the specific facts
of their situation. ISDA, FIA, IA, GFXD, EFAMA, BVI and EVIA assumes no responsibility
for any use of this document and undertakes no duty to update it to reflect future
regulatory or market developments. Each market participant should satisfy itself that
following or not following the EMIR Best Practices set out herein is appropriate to their
specific circumstances.
UNDER NO CIRCUMSTANCES SHALL ISDA, FIA, IA, GFXD, EFAMA, BVI AND/OR EVIA BE
LIABLE TO ANY PARTY, REGARDLESS OF THE FORM OF ACTION, ARISING FROM OR IN
CONNECTION WITH INFORMATION IN THIS DOCUMENT OR ANY PERSON'S USE OF THIS
DOCUMENT, OR FOR ANY DIRECT, INDIRECT, SPECIAL, CONSEQUENTIAL, INCIDENTAL,
PUNITIVE OR ANY OTHER DAMAGES THAT MAY RESULT FROM THE USE OF THIS
DOCUMENT.
EMIR Regulatory Reporting Best Practices
Purpose
The EMIR Reporting Best Practices, for both over-the-counter derivative (OTC) and exchange traded derivative (ETD) reporting, is
relevant reporting Working Groups or Committees of each trade association. The working groups and committees comprised of a w
fields which would benefit from establishing best practices. These fields were identified by a combination of isolating the fields whic
scenario would benefit from additional guidance. The working groups / committees reviewed and agreed to the reporting best prac
these best practices is to provide an agreed and standardised market guide for firms to utilize in order to comply with EMIR OTC a
any determinations made within these EMIR best practices.
The trade associations participating in the establishment of these best practices are International Swaps and Derivatives Associati
Investment Funds Association (BVI), European Fund and Asset Management Association (EFAMA), and European Venues & Inter
Commentary
The best practice matrix has been established based on the EMIR validation table, (as published by ESMA), which contains the Re
The intention is for these EMIR Reporting Best Practices to be widely accepted as standard market practice which complements th
EMIR Q&A documents, and are designed to adhere to the published EMIR validation rules. The best practices have been shared w
reporting document which are endorsed by regulators. The best practices may be updated periodically, for example when an upda
time.
The Validation rules define fields as being either 'Mandatory', 'Conditional' or 'Optional'. These categories relate to the checks Trad
a field is identified as 'Optional', the field must be populated if it is relevant for the contract being reported, i.e. all fields are mandat
As well as the main 'Industry Best Practice matrix', additional best practices based on specific scenarios are captured with the tabs
For the avoidance of doubt, although they may be some overlap between the EMIR reporting requirements and the reporting requi
Contact details
waps and Derivatives Association (ISDA), Futures Industry Association (FIA), the Global Foreign Exchange Division (GFXD) of GFMA, the Investment Asso
, and European Venues & Intermediaries Association (EVIA).
ESMA), which contains the Regulatory Technical Standards (RTS), the Implementation Technical Standards (ITS) and validation rules.
practice which complements the EMIR reporting RTS and ITS. Where possible these guidelines are designed to be consistent with other published reportin
t practices have been shared with ESMA and several NCAs to preview before being published, but for the avoidance of doubt, these best practices are not
lly, for example when an updated EMIR Q&A document is published or to add practices to further fields, but where possible the guidelines, once set, will re
ories relate to the checks Trade Repositories are to perform on a field and do not refer to whether the reporting party as the option to populate the field or n
orted, i.e. all fields are mandatory when they are relevant to the contract.
arios are captured with the tabs and/or via links within the main matrix.
ements and the reporting requirements of other global reporting regimes, these best practices are specific to EMIR reporting.
ticipants through a series of discussions held within the
and their members identified the EMIR trade reporting
by member firms where a given field, product or
ocuments referred to within the matrix. The intention of
No firm is legally bound or compelled in any way to follow
alidation rules.
ing.
"M" - Mandatory: the field is strictly required and validations of format and content are applied.
"C" - Conditionally mandatory: the field is required if the specific conditions set out in the validation rules are met. Format and
content validations
EMIR validation areESMA
table applied
"O" - Optional: the field shall be populated if applicable. Only format and content validations are applied when the field is populated.
"-" - Not relevant: the field shall be left blank
Validations
(published 03/04/2017)
Technical standards ESMA published updated on 20/12/2019. Amendments are marked in red font and are to Best Practice Links Comment
apply no later than 20 June 2020, but may be implemented by Trade Repositories prior to
that date.
Is itTrade level
Mandatory, IsPosition level
it Mandatory,
Conditional, Optional Conditional, Optional -Conditions Matching / Pairing
Table Item Section Field Details to be reported Format OTC ETD Justification for best practice where applicable
or Not relevant for a or Not relevant for a -Format and content field
N given
M E action
C R type?
Z V P N given
M E action
C R type?
Z V P
In the case where the reporting When populated, shall contain a valid LEI
counterparty has delegated the submission
included in the GLEIF database maintained by
1 9 Parties to the Report submitting entity ID of the report to a third party or to the ISO 17442 Legal Entity Identifier (LEI) 20 O O - - O - - O O O - - O - the Central Operating Unit. The status of the N No best practice prepared for this field No best practice prepared for this field
contract other counterparty, this entity has to be alphanumerical character code
LEI shall be "Issued", "Pending transfer" or
identified in this field by a unique code.
Otherwise this field shall be left blank. "Pending archival".
B = Buyer
Parties to the Identifies whether the reporting Shall contain only one of the following
1 14 Counterparty side S = Seller M O - - O - - M M O - - O - Y No best practice prepared for this field No best practice prepared for this field
contract counterparty is a buyer or a seller values: "B" or "S". 1 alphabetical character.
Populated in accordance with Article 3a
Date and time of the last valuation. For If field 1.17 is populated, this field shall be
Parties to the mark-to-market valuation the date and ISO 8601 date in the UTC time format YYYY- populated in a common input format: YYYY- This field shall be left blank for transaction-level. Report OTC – Reporting entities generate the valuation amounts at different
1 19 Valuation timestamp C - - - - - C - C - - - - C N No best practice prepared for this field a default timestamp of '23:59:00' for position-level times, depending on their internal systems. Therefore, it is extremely
contract time of publishing of reference prices shall MM-DDThh:mm:ssZ MM-DDThh:mm:ssZ
reports difficult to match on the time element of this value.
be reported. Otherwise, the field shall be left blank.
When populated:
Value of the initial margin posted by the Up to 20 numerical characters including up to
reporting counterparty to the other Up to 20 numerical characters including 19 decimals.
counterparty. decimals. The decimal mark is not counted as a
1 24 Parties to the Initial margin posted Where initial margin is posted on a The decimal mark is not counted as a O - - - - - O - O - - - - O numerical character. If populated, it shall be N No best practice prepared for this field
contract
portfolio basis, this field should include the numerical character. If populated, it shall be represented with a dot.
overall value of initial margin posted for represented by a dot. Negative values are not allowed.
the portfolio.
When populated:
Value of the variation margin posted, Up to 20 numerical characters including up to
including cash settled, by the reporting Up to 20 numerical characters including 19 decimals.
Parties to the counterparty to the other counterparty. decimals. The decimal mark is not counted as a
1 26 Variation margin posted Where variation margin is posted on a The decimal mark is not counted as a O - - - - - O - O - - - - O numerical character. If populated, it shall be N No best practice prepared for this field
contract
portfolio basis, this field should include the numerical character. If populated, it shall be represented with a dot.
overall value of variation margin posted for represented by a dot. Negative values are not allowed.
the portfolio.
When populated:
Value of the initial margin received by the Up to 20 numerical characters including up to OTC - ISDA have produced a document for the principles for Collateral
reporting counterparty from the other Up to 20 numerical characters including 19 decimals. See Comment •See EMIR reporting RTS-ITS
and Valuation
- collateral
reporting
and valuation
are found
fields
within
BESTthe
PRACTICE
'EMIR reporting
v6 RTS-ITS -
counterparty. decimals. The decimal mark is not counted as a collateral and valuation fields Best Practice'.
Parties to the
1 28 Initial margin received Where initial margin is received on a The decimal mark is not counted as a O - - - - - O - O - - - - O numerical character. If populated, it shall be N No best practice prepared for this field
contract
portfolio basis, this field should include the numerical character. If populated, it shall be represented with a dot.
overall value of initial margin received for represented by a dot. Negative values are not allowed.
the portfolio.
When populated:
Value of the variation margin received, Up to 20 numerical characters including up to
including cash settled, by the reporting Up to 20 numerical characters including 19 decimals.
counterparty from the other counterparty. decimals. The decimal mark is not counted as a
Parties to the
1 30 Variation margin received Where variation margin is received on a The decimal mark is not counted as a O - - - - - O - O - - - - O numerical character. If populated, it shall be N No best practice prepared for this field
contract portfolio basis, this field should include the numerical character. If populated, it shall be represented with a dot.
overall value of variation margin received represented by a dot. Negative values are not allowed.
for the portfolio.
When populated:
Up to 20 numerical characters including up to
Up to 20 numerical characters including 19 decimals.
decimals. The decimal mark is not counted as a
1 32 Parties to the Excess collateral posted Value of collateral posted in excess of the O - - - - - O - O - - - - O N No best practice prepared for this field
The decimal mark is not counted as a numerical character. If populated, it shall be
contract required collateral numerical character. If populated, it shall be represented with a dot.
represented by a dot. Negative values are not allowed.
When populated:
Up to 20 numerical characters including up to
Up to 20 numerical characters including 19 decimals.
decimals. The decimal mark is not counted as a
1 34 Parties to the Excess collateral received Value of collateral received in excess of the O - - - - - O - O - - - - O N No best practice prepared for this field
contract required collateral The decimal mark is not counted as a numerical character. If populated, it shall be
numerical character. If populated, it shall be represented with a dot.
represented by a dot. Negative values are not allowed.
CO = Commodity and emission allowances Note: Reportable fields are not limited only to those
Validation rules do not prohibit fields which relate to a specific asset
CR = Credit Shall only contain one of the following applicable to the specified asset class, i.e. validation rules do This field will be populated with "CO", "CU", "EQ" or
2 2 Section 2a - Asset class Each reported contract shall be classified CU = Currency M O - - O - - M M O - - O - values: "CO", "CR", "CU", "EQ" or "IR". 2 Y not prevent firms from populating fields that fall under a "IR" and is subject to the CFI code populated in field 2.4 class in the 'Section' column from being populated for other asset
Contract type according to the asset class it is based on classes when applicable, e.g. FX fields to be populated for a cross
EQ = Equity alphabetical characters. different asset class (as per the 'Section' column) to the one below.
currency swap.
IR = Interest Rate specified in field 2.2.
Section 2b –
2 3 Contract Product classification type The type of relevant product classification C = CFI M O - - O - - M M O - - O - Until UPI is endorsed by ESMA, this field shall Y No best practice prepared for this field No best practice prepared for this field
U = UPI only contain "C". 1 alphabetical character.
information
Validations
(published 03/04/2017)
Technical standards ESMA published updated on 20/12/2019. Amendments are marked in red font and are to Best Practice Links Comment
apply no later than 20 June 2020, but may be implemented by Trade Repositories prior to
that date.
Is itTrade level
Mandatory, IsPosition level
it Mandatory,
Conditional, Optional Conditional, Optional -Conditions Matching / Pairing
Table Item Section Field Details to be reported Format OTC ETD Justification for best practice where applicable
or Not relevant for a or Not relevant for a -Format and content field
N given
M E action
C R type?
Z V P N given
M E action
C R type?
Z V P
Note. For FX Options, the FpML model determines the notional currency
based on whether the option is a Call or Put. i.e. if option is sold a Call,
Where there is more than one notional amount, sort the This field is dependent on the specific contract details then the notional amount will be in the Call currency, and therefore
The currency of the notional amount. currencies alphabetically by ISO 4217 standard and report
Section 2b – Shall be populated with ISO 4217 Currency and should not be ordered alphabetically. Notional 'National currency 1' would be the Call currency. Similarly, if sold a Put
2 9 Notional currency 1 In the case of an interest rate or currency ISO 4217 Currency Code, 3 alphabetical M O - - O - - M M O - - O - Y the first currency as Notional currency 1.
Contract derivative contract, this will be the notional characters Code (official list only), 3 alphabetical Currency 1 is directly linked with the Notional, which is option, FpML will show the notional in the Put currency, so 'Notional
information characters. directly linked to the price, which is directly linked to currency 1' would also be the Put currency.
currency of leg 1. Note: See exception for FX Options, where best practice for
FX Option contracts is under review. the specific contract details. Therefore, firms submitting by FpML cannot follow the best practice of
sorting currencies alphabetically when reporting FX Options.
A resolution to the best practice for FX Options is under review.
Note. For FX Options, the FpML model determines the notional currency
based on whether the option is a Call or Put. i.e. if option is sold a Call,
Where there is more than one notional amount, sort the then the notional amount will be in the Call currency, and therefore
The other currency of the notional amount. currencies alphabetically by ISO 4217 standard and report As set out in field 2.9, this field is dependent on the
Section 2b – When populated: 'National currency 1' would be the Call currency. Similarly, if sold a Put
2 10 Contract Notional currency 2 In the case of an interest rate or currency ISO 4217 Currency Code, 3 alphabetical O O - - O - - O O O - - O - ISO 4217 Currency Code (official list only), 3 Y the second currency as Notional currency 2. specific contract details. As such, Notional Currency 2 is option, FpML will show the notional in the Put currency, so 'Notional
derivative contract, this will be the notional characters the opposite currency (the base currency) to Notional
information alphabetical characters. currency 1' would also be the Put currency.
currency of leg 2. Note: See exception for FX Options, where best practice for currency 1.
FX Option contracts is under review. Therefore, firms submitting by FpML cannot follow the best practice of
sorting currencies alphabetically when reporting FX Options.
A resolution to the best practice for FX Options is under review.
Validations
(published 03/04/2017)
Technical standards ESMA published updated on 20/12/2019. Amendments are marked in red font and are to Best Practice Links Comment
apply no later than 20 June 2020, but may be implemented by Trade Repositories prior to
that date.
Is itTrade level
Mandatory, IsPosition level
it Mandatory,
Conditional, Optional Conditional, Optional -Conditions Matching / Pairing
Table Item Section Field Details to be reported Format OTC ETD Justification for best practice where applicable
or Not relevant for a or Not relevant for a -Format and content field
N given
M E action
C R type?
Z V P N given
M E action
C R type?
Z V P
Section 2c - A unique number for the group of reports Up to 52 alphanumerical characters where
2 13 Details on the Report tracking number which relate to the same execution of a An alphanumeric field up to 52 characters O O - - O - - M O O - - O - any character is allowed. N No best practice prepared for this field No best practice prepared for this field
transaction derivative contract
FX products:
General principle:
Date and time a transaction was originally executed, resulting
in the generation of a new UTI.
General principle wording is taken from CPMI-IOSCO CDE definition of
The Execution Timestamp remains unchanged throughout Execution timestamp.
the life of the contract and will only changes when the UTI
For transaction-level reports, this field shall be
changes / a new UTI is generated. populated with the timestamp provided by the CCP For cleared trades, it is understood that the intention of regulators is
(UTC). always to receive the MIC of the alpha trade, mechanically therefore
Section 2c - For the avoidance of doubt:
2 25 Details on the Execution timestamp Date and time when the contract was ISO 8601 date in the UTC time format YYYY- M O - - O - - M O O - - O - This field shall be populated in a common Y Novations – the novation timestamp forcing the presence of the instrument ISIN into the reporting.
executed MM-DDThh:mm:ssZ input format: YYYY-MM-DDThh:mm:ssZ. For give-ups, this field shall be populated with time of By extension this meant that the execution timestamp should also be
transaction Cleared trades – the Execution Timestamp of the alpha trade
is available, otherwise the clearing timestamp give-up rather than original execution time. that of the alpha trade.
The timestamp of the alpha trade is received in the clearing request
Amendments – persist the original Execution Timestamp, i.e.
For position reports, this field shall be left blank. message from the trading platforms or the middleware.
not the timestamp of the amendment event. If a CCP does not have an Execution timestamp of the alpha trade, only
Allocations – the Execution Date&Time of the original Block
then would they use the clearing timestamp.
trade.
• Event and Product specific: While the RTS definition could be interpreted to mean the date the
contract was entered into (i.e. Trade Date) is to be reported, the best
• Amendments – persist the original Execution Timestamp,
practice is to report the Effective Date as agreed on the contract for the
i.e. do not reflect the timestamp of the amendment event. following reasons:
• Cleared trades – see best practice for Execution
Timestamp. o EMIR Q&A TR Question 48 asks “How should the Effective date… be
• Swaptions: Report the execution date of the contract,
Section 2c - reported if it is not specified as part of the terms of the contract?” . This
2 26 Date when obligations under the contract This field shall be populated in a common (note, the Effective Date of the underlyer is not to be used Current assumption is that this will always be the same
Details on the Effective date come into effect
ISO 8601 date in the format YYYY-MM-DD M O - - O - - M O O - - O -
input format: YYYY-MM-DD.
Y
for this field) as the trade date. implies that if the contract has an Effective Date, that is the date to
transaction report.
• Novations:
o For new trades (between Transferee/ Transferee1 and o The CPMI IOSCO definition for Effective Date is “Unadjusted date at
which obligations under the OTC derivative transaction come into effect,
Remaining Party/ Transferee 2), either:
as included in the confirmation.” Specifying that it is the date included in
(1) if the effective date of the trade is in the past, then report the confirmation validates it is the contractually agreed date to be
the Novation Date of the novation agreement, or
reported.
(2) if the effective date of the trade is a future date and is yet
to occur (i.e. a forward starting swap which has been
novated between the Trade Date and the Effective Date),
then report that future effective date of the trade.
o For partial or full novation between Remaining Party and
the Transferor, report the original Effective Date for the
transaction.
The timestamp is only reset when there is a new UTI, i.e. The original Confirmation timestamp is persisted for all post trade
events, unless such event results in a new contact / UTI.
once a confirmation timestamp has been reported, it is to be
persisted for the life of the contract.
Breaks can be caused by one party reporting the Confirmation
If field 2.33 is populated with "Y" or "E", this Timestamp of a post trade event, while the other persists the original
field shall be populated in a common input The value reported is the date and time the confirmation is datetime.
matched, not the time confirmations are sent.
format: YYYY-MM-DDThh:mm:ssZ. It was reasoned that the original timestamp should persist based on:
Section 2d - The value of this field shall be greater than or • The RTS definition's reference to Article 12 of Commission Delegated
Date and time of the confirmation, as set For electronic confirmations, the timestamp provided by the
2 32 Risk Confirmation timestamp ISO 8601 date in the UTC time format YYYY- C O - - O - - C O O - - O - equal to the value of the field 2.25 unless the Y This field shall remain blank for transaction and Regulation (EU) No 149/2013(3) which refers to 'Timely Confirmations'
out in Article 12 of Commission Delegated confirmation platform should be used.
mitigation / Regulation (EU) No 149/2013 MM-DDThh:mm:ssZ default date is used. position reports. in the context of 'date of execution' only.
Reporting "1900-01-01T00:00:00Z" is accepted when • The EMIR Q&A, OTC question 15 infers that Confirmation Timestamp is
Confirmation timestamp is only a matching field for
the actual value is not available. electronic confirmations (as verified with several TR's). only updated for the original submission, "The timely confirmation of
If field 2.33 is populated with "N", this field OTC derivative contracts applies wherever a new derivatives contract is
Therefore, although Confirmation timestamp is to be
shall be left blank. concluded"
populated when Confirmation Means is set to either "Y" or • In consideration to more standardisation between global reporting
"E", Confirmation timestamp will only be a matching field
regimes, the CPMI IOSCO CDE definition for Confirmed (2.18) refers to
when the value is "E". new transactions only.
Non-cleared
• If Venue of Execution has a MIC, report as “N”
• Otherwise report “E” or “Y”. Note 1: Reason why cleared trades are reported as “E” is because CCPs
Therefore, when executed on an SI, the expectation is that confirm cleared trades with both parties to the alpha trade, and with TR
there will be a confirmation. Question 50 of the EMIR Q&A referring to derivatives “traded on a
trading venue”, i.e. referring to the original alpha trade and not the
Best practice definitions: cleared trade, it is logical to report cleared trades as “E”.
Section 2d -
Risk Whether the contract was electronically Y = Non-electronically confirmed Shall contain only one of the following • E (Electronically Confirmed): This should be used if the This field shall be populated with "N" in all cases. This
2 33 Confirmation means confirmed, non-electronically confirmed or N = Non-confirmed M O - - O - - M O O - - O - values: "Y", N" or "E". 1 alphabetical Y trade is Confirmed by means of matching electronic Note 2: Reasoning why an OTC non-cleared trade executed on a venue is
mitigation / aligns with EMIR TR Answer 50.
Reporting remains unconfirmed E = Electronically confirmed character. messages sent by each party to the other or by each party to reported as “N”, is because EMIR Q&A (TR Question 50) states that "N"
a third party system. Such electronic messaging systems is to be reported if the derivative “does not have to be confirmed”.
include, without limitation, SWIFT, CLS, DSMatch, Traiana, While a confirmation may still be issued for an OTC traded on a venue,
Markit and any other such systems used by or agreed to the trading venue will hold the details of the trade that both parties
between the parties hereto from time to time. agreed to and so a confirmation is not a necessary requirement.
The EMIR Q&A (TR Question 42) provides guidance on how to report for
• Report as "N" for all cleared trades, (per EMIR Q&A TR
transactions executed on a regulated market and for cleared trades (as
Question 42 (c2). The fields Cleared (2.35) is to be populated of May 2019).
with "Y".
OTC -
• Report as "X" if the product is not subject to mandatory
• The Q&A (TR 42.c(c2)) says to populate as "N" for all cleared trades.
If field 2.15 is not populated with a MIC code clearing, (unless or until the trade is cleared).
Indicates, whether the reported contract of a regulated market, or of a third-country
belongs to a class of OTC derivatives that • The Q&A has removed all reference to the value "X", but it remains a
market considered as equivalent to a • Report as "Y" if:
has been declared subject to the clearing regulated market, this field shall be (i) the product is subject to the clearing obligation, i.e. the permitted value within the Validation rules. Members propose to retain
Section 2e - obligation and both counterparties to the Y = Yes a scenario for reporting "X", where it will be used to represent products
2 34 Clearing obligation C O - - O - - C C O - - O - populated and shall contain one of the Y product is subject to mandatory clearing (as per the RTS This field shall always be left blank. •See 'EMIR Clearing product classes schedule and Clearing Obligation flag'
Clearing contract are subject to the clearing N = No which are not subject to mandatory clearing.
obligation under Regulation (EU) No following values "Y" or "N". official journal AND Once a trade reported as “X” is cleared, a value of “N” is to be reported.
'X' is accepted when the actual value is not (ii) both counterparties are subject to the clearing obligation,
648/2012, as of the time of execution of
the contract available. AND • The Q&A guidance and RTS read that the value "Y" is only reported if
1 alphabetical characters. (iii) has not yet been cleared, THEN
the contract AND the counterparties are subject to mandatory clearing,
Report as "Y".
BUT the trade has not yet been cleared.
• See 'EMIR Clearing product classes schedule and Clearing
Obligation flag' for additional best practice guidance for the ETD - The Q&A (TR 42.c(c1)) says to leave the field blank for transactions
executed on a regulated market.
products specified in the official journal).
2 35 Section 2e - Cleared Indicates, whether clearing has taken place Y = Yes M O - - O - - M M O - - O - Shall contain only one of the following values Y No best practice prepared for this field This field shall be populated with 'Y' in all cases.
Clearing N = No "Y" or "N". 1 alphabetical character.
The initial proposal for a Zero Coupon Swap was to report “0Y”, but this
value will not be accepted within the FpML framework. Therefore, a
Time period describing how often the
If field 2.39 is populated and field 2.1 is not best practice of “999Y” was proposed instead to distinguish a swap with
counterparties exchange payments, whereby populated with "FR", then this field shall be payment at maturity from a normal yearly coupon.
Time period describing frequency of the following abbreviations apply:
2 43 Section 2f - Fixed rate payment frequency leg 1 –time C O - - O - - C C O - - O - populated and shall contain only one of the N No best practice prepared for this field
payments for the fixed rate leg 1, if Y = Year
Interest Rates period applicable M = Month following values: "Y", "M", W" or "D". 1 MiFIR data reporting Q&A, section 13 'Reference Data for financial
alphabetic character. instruments’, covers a similar scenario and advises to report “0 ‘DAYS’”.
W = Week
D = Day Otherwise the field shall be left blank. This would translate to reporting "0D" for EMIR, but again with will not
be accepted within the FpML framework and so "999Y" remains the best
practice.
Integer multiplier of the time period If field 2.58 is populated and field 2.1 is not
Multiplier of the time period describing populated with "FR", then this field shall be The initial proposal for a Zero Coupon Swap was to report “0Y”, but this
2 50 Section 2f - Floating rate payment frequency leg 2 – describing how often the counterparties C O - - O - - C C O - - O - N No best practice prepared for this field No best practice prepared for this field value will not be accepted within the FpML framework. Therefore, a
frequency of payments for the floating rate populated and shall contain up to 3
Interest Rates multiplier leg 2, if applicable exchange payments. numerical characters. best practice of “999Y” was proposed instead to distinguish a swap with
Up to 3 numerical characters. payment at maturity from a normal yearly coupon.
Otherwise the field shall be left blank.
MiFIR data reporting Q&A, section 13 'Reference Data for financial
instruments’, covers a similar scenario and advises to report “0 ‘DAYS’”.
This would translate to reporting "0D" for EMIR, but again with will not
Time period describing how often the be accepted within the FpML framework and so "999Y" remains the best
counterparties reset the floating rate, If field 2.55 is populated, then this field shall practice.
Section 2f - Floating rate reset frequency leg 1 – time Time period describing frequency of whereby the following abbreviations apply: be populated and shall contain only one of
2 51 Y = Year C O - - O - - C C O - - O - the following values: "Y", "M", W" or "D". 1 N No best practice prepared for this field No best practice prepared for this field
Interest Rates period floating rate leg 1 resets, if applicable
M = Month alphabetic character.
W = Week Otherwise the field shall be left blank.
D = Day
Integer multiplier of the time period If field 2.55 is populated, then this field shall
Section 2f - Floating rate reset frequency leg 1 - Multiplier of the time period describing describing how often the counterparties reset be populated and shall contain up to 3
2 52 frequency of floating rate leg 1 resets, if C O - - O - - C C O - - O - N No best practice prepared for this field No best practice prepared for this field
Interest Rates multiplier the floating rate. numerical characters.
applicable Up to 3 numerical characters. Otherwise the field shall be left blank.
Multiplier of the time period describing Integer multiplier of the time period If field 2.58 is populated, then this field shall
Section 2f - Floating rate reset frequency leg 2 - describing how often the counterparties reset be populated and shall contain up to 3
2 54 frequency of floating rate leg 2 resets, if C O - - O - - C C O - - O - N No best practice prepared for this field No best practice prepared for this field
Interest Rates multiplier the floating rate. numerical characters.
applicable Up to 3 numerical characters. Otherwise the field shall be left blank.
Validations
(published 03/04/2017)
Technical standards ESMA published updated on 20/12/2019. Amendments are marked in red font and are to Best Practice Links Comment
apply no later than 20 June 2020, but may be implemented by Trade Repositories prior to
that date.
Is itTrade level
Mandatory, IsPosition level
it Mandatory,
Conditional, Optional Conditional, Optional -Conditions Matching / Pairing
Table Item Section Field Details to be reported Format OTC ETD Justification for best practice where applicable
or Not relevant for a or Not relevant for a -Format and content field
N given
M E action
C R type?
Z V P N given
M E action
C R type?
Z V P
AG = Agricultural
EN = Energy
Section 2h - 'If field 2.2 is populated with "CO", this field
Commodities FR = Freights shall be populated and shall contain only one
Indicates the type of commodity underlying ME = Metals
2 65 and emission Commodity base C O - - O - - C C O - - O - of the following values: "AG", "EN", "FR", Y No best practice prepared for this field No best practice prepared for this field
allowances the contract IN = Index "ME", "IN", "EV", "EX", "OT". 2 alphabetical
EV = Environmental
(General) characters.
EX = Exotic
OT = Other
Agricultural
GO = Grains oilseeds 'If field 2.65 is populated with "AG", this field
DA = Dairy shall be populated and shall contain only one
LI = Livestock of the following values: "GO", "DA", "LI",
FO = Forestry "FO", "SO", "SF" or "OT". 2 alphabetical
SO = Softs characters.
SF = Seafood If field 2.65 is populated with "EN", this field
OT = Other shall be populated and shall contain only one
Energy of the following values: "OI", "NG", "CO",
OI = Oil "EL", "IE" or "OT". 2 alphabetical characters.
NG = Natural gas If field 2.65 is populated with "FR", this field
Section 2h -
Commodities CO = Coal shall be populated and shall contain only one
Details of the particular commodity beyond EL = Electricity of the following values: "DR" , "WT" or "OT".
2 66 and emission Commodity details C O - - O - - C C O - - O - Y No best practice prepared for this field No best practice prepared for this field
allowances field 65 IE = Inter-energy 2 alphabetical characters.
OT = Other If field 2.65 is populated with "ME", this field
(General)
Freights shall be populated and shall contain only one
DR = Dry of the following values: "PR" or "NP". 2
WT = Wet alphabetical characters.
OT = Other If field 2.65 is populated with "EV", this field
Metals shall be populated and shall contain only one
PR = Precious of the following values: "WE" , "EM" or "OT".
NP = Non-precious 2 alphabetical characters.
Environmental If field 2.65 is populated with "IN", "EX" or
WE = Weather "OT", this field shall be left blank.
EM = Emissions
OT = Other
BL = Base Load
If field 2.67 or 2.68 is populated with EIC
Section 2h - PL = Peak Load
code, this field shall be populated and shall
Commodities OP = Off-Peak contain one of the following values: "BL",
2 69 and emission Load type Identification of the delivery profile BH = Hour/Block Hours C O - - O - - C C O - - O - N No best practice prepared for this field No best practice prepared for this field
"PL", "OP", "BH", "SH", "GD" or "OT". 2
allowances SH = Shaped alphabetical characters.
(Energy) GD = Gas Day
Otherwise the field shall be left blank.
OT = Other
N=Minutes
If field 2.67 or 2.68 is populated with EIC
H= Hour
Section 2h - D= Day code, this field shall be populated and shall
contain one of the following values: "N", "H",
Commodities W=Week
2 73 and emission Duration The duration of the delivery period M=Month C O - - O - - C C O - - O - "D", "W", "M", "Q", "S", "Y" or "O". 1 N No best practice prepared for this field No best practice prepared for this field
alphabetical character.
allowances Q = Quarter
Otherwise the field shall be left blank.
(Energy) S= Season This field is repeatable.
Y= Annual
O=Other
WD = Weekdays
WN = Weekend
MO = Monday If field 2.67 or 2.68 is populated with EIC
Section 2h - TU = Tuesday code, this field shall be populated and shall
Commodities WE = Wednesday contain one of the following values: "WD",
2 74 and emission Days of the week The days of the week of the delivery TH = Thursday C O - - O - - C C O - - O - "WN", "MO", "TU", "WE", "TH", "FR", "SA", N No best practice prepared for this field No best practice prepared for this field
allowances FR = Friday "SU". 2 alphabetical character.
(Energy) SA = Saturday Otherwise the field shall be left blank.
SU = Sunday This field is repeatable.
Multiple values separated by "/ " are
permitted
KW
KWh/h
KWh/d If field 2.67 or 2.68 is populated with EIC
MW
code, this field shall be populated and shall
MWh/h
Section 2h - MWh/d contain one of the following values: "KW",
Commodities Daily or hourly quantity in MWh or kWh/d "KWh/h", "KWh/d", "MW", "MWh/h",
2 76 Quantity Unit GW C O - - O - - C C O - - O - N No best practice prepared for this field No best practice prepared for this field
and emission which corresponds to the underlying GWh/h "MWh/d", "GW", "GWh/h", "GWh/d",
allowances commodity "Therm/d", "KTherm/d", "MTherm/d",
GWh/d
(Energy) "cm/d" or "mcm/d".
Therm/d Otherwise the field shall be left blank.
KTherm/d
This field is repeatable.
MTherm/d
cm/d
mcm/d
Indicates whether the option may be A = American If field 2.1 (Contract type) is populated with Reasoning for CapFloors to be reported as "E" is that such products
exercised only at a fixed date (European, B = Bermudan "OP" or "ST" this field shall be populated and This field is populated in line with the information would report field 2.1 (Contract Type) as "OP" and therefore it is
Section 2i -
2 79 Option exercise style and Asian style), a series of pre-specified E = European C O - - O - - C C O - - O - shall contain one of the following values: Y For Caps and Floors, populated with "E" (European) contained in the exchange documentation/CCP file or required to populate the Option exercise style. While a CapFloor would
Options dates (Bermudan) or at any time during the S = Asian "A", "B", "E" ,"S", "AS", "BS" or "ES". Up to 2 static data provider. not have an exercise style, there is no option to report 'Other'.
life of the contract (American style) More than one value is allowed alphabetical characters. Therefore, best practice is be to report as European "E".
A new version of a series is issued if one of If field 2.2 (Asset class) is populated with
Section 2j – the constituents defaults and the index has "CR"and field, 2.7 (Underlying identification
2 88 Credit Version to be re-weighted to account for the new Integer field up to 5 characters C O - - O - - C C O - - O - type) is populated with "X", this field shall be Y No best practice prepared for this field No best practice prepared for this field
derivatives number of total constituents within the populated with a positive integer value. Up
index to 5 numerical characters.
*Fields 67 – 77 apply only to derivative contracts related to Natural Gas and Electricity delivered in the EU.
*Fields 70 - 77 are repeatable
EMIR fields
RTS 22 fields Last Review
NB: this may contradict MiFIR approach
Instrument
Product identification
Number Scenario Instrument ToTV? Venue of execution Type
Venue Identificati Comment
(field 2.15) (field 2.5) (field 36) on code
(field 41)
Reportable trade executed on EEA Trading Venue Y MIC of Trading Venue I MIC of Trading Venue I
1 (defined as Regulated Markets, MTFs and OTFs)
Reportable post-trade event of a trade executed on MIC of Trading Venue MIC of Trading Venue to be Post trade events should reflect where the trade was originally
EEA Trading Venue (defined as Regulated Markets, Y I I
to be peristed peristed executed. Therefore the MIC initially reported should be persisted.
2 MTFs and OTFs)
Reportable trade executed on EEA trading venue (i.e. MIC of Trading Venue
Y if available, otherwise I MIC of Trading Venue I Uncapitalised "trading venue" to represent a trade exected on a
multidealer platform) which is not defined as a venue which is not classified as an RM, MTF or OTF.
3 Regulated Markets, MTFs and OTFs) XOFF
Reportable post trade event (decrease of position) MiFID s/b MIC of the SI or "XOFF".
MIC of SI if available, otherwise
effected by post trade service not on EEA Trading Y XOFF I I
XOFF
12 Venue EMIR no change
EMIR -
The Beta / Gamma trades will reflect the Venue of Execution value
Retain Venue of
of the Alpha Trade. This conclusion has been made based on an
Execution value of the FCA interpretation that regulators want to know where the original
alpha trade, i.e. MIC of execution took place, regardless of it being the cleared trade that
Trading Venue. is being reported.
Y Post-cleared events: I N/A {blank} Subsequent post-trade events are to persist the value of Venue of
persist the VofE value Exercise, except for compression events (resulting in a new trade
except following a and UTI), where "XXXX" is to be populated.
compression event See scenario 20 for the reasoning why Venue of Execution is
which is reported as populated as "XXXX" for trades resulting from a compression
"XXXX"
event.
Reportable Cleared trade (Beta trade post clearing)-
15 executed on EEA Trading Venue MiFID - Cleared trades aren't reportable under MiFID
Retain Venue of
Execution value of the
alpha trade: "XOFF"
EMIR - see scenario 15
Y Post-cleared events: I N/A {blank}
persist the VofE value
except following a MiFID - Cleared trades aren't reportable under MiFID
compression event
which is reported as
Reportable Cleared trade (Beta trade post "XXXX"
16 clearing) - executed off venue
Retain Venue of
Execution value of the
alpha trade.
EMIR - see scenario 15
Post-cleared events:
Y I N/A {blank}
persist the VofE value
except following a MiFID - Cleared trades aren't reportable under MiFID
compression event
which is reported as
Reportable Cleared trade (Beta trade post "XXXX"
17 clearing) - non EEA venue
Retain Venue of
Execution value of the
alpha trade: "XOFF"
EMIR - see scenario 15
Post-cleared events:
Y persist the VofE value
I N/A {blank}
except following a MiFID - Cleared trades aren't reportable under MiFID
compression event
which is reported as
Reportable Cleared trade (Beta trade post "XXXX"
18 clearing) - executed on Systematic Internaliser
EMIR - see scenario 15
NB. In this scenario, the alpha trade would have been reported as
N XXXX {blank} N/A {blank} "XXXX"
Reportable Cleared trade (Beta trade post MiFID - Cleared trades aren't reportable under MiFID
19 clearing) - executed on Systematic Internaliser
Original
Unallocated No Yes
Trade Allocated “Block” Trade
Yes (one per
Allocated Trades Yes
allocation)
Original Bilateral
No Yes
Trade "alpha"
Cleared Positions
Yes (one for
("beta" and Yes
each)
Cleared Positions "gamma")
Original
Unallocated No Yes
“Block” Trade
Bankruptcy /
Failure to Pay / Yes No
Other
Restructuring - Full
Yes No
Trigger
Restructuring -
Partial Trigger - Yes No
original trade
Restructuring -
Partial Trigger -
new trade
Yes Yes
(remaining
untriggered
notional)
Credit Events
Credit Events
Restructuring -
Partial Trigger -
Yes Yes
new trade (triggered
notional)
Original Trade -
Yes No
Terminated
Original Trade
Amendment - Yes No
Increase
Original Trade
Amendment - Yes No
Decrease
Compression Events
Yes (one or
Package Transactions n/a No
multiple)
*These columns are based on the stated intention of DTCC to add a separate field to capture original
execution timestamp. These columns reflect WG thoughts on how execution timestamp might be
reflected in a two-field approach, but are subject to further information from DTCC and further WG
consideration.
EMIR
Execution Timestamp
Comment
Date&Time trade
agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time block
trade agreed
Date&Time block Bank of England guidance is to report the Execution Date&Time
trade agreed of the original Block trade.
Date&Time [original]
trade agreed
Date&Time block
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time of
novation consent
n/a
Date&Time [original]
trade agreed
Date&Time of
novation consent
n/a
Date&Time [original]
trade agreed
Date&Time of exercise
n/a
Date&Time of EB-
client execution
Date&Time of PB
acceptance
Date&Time [original]
trade agreed
Date&Time [original] This is a contractual event, and not a lifecycle event. Therefore
trade agreed the 'Date&Time [original] trade agreed' is to be reported.
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original] Follow existing EMIR guidance instead of aligning with CFTC
trade agreed for this scenario.
Date&Time [original] Follow existing EMIR guidance instead of aligning with CFTC
trade agreed for this scenario.
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time [original]
trade agreed
Date&Time
compression cycle
completed
Original Date&Time
of acceptance to
clearing
Date&Time
compression cycle
completed
Date&Time contract
agreed
Date&time all
components of
package are known
Best Practice Proposal For Leg 1 / Leg 2 Determination and population of Counterparty Side for EMIR RTS 2.0
Theensure
To below that
tabletrades
showsare
how to determine
reported which for
consistently legmatching
is Leg 1 and the Counterparty
purposes, Side formust
FpML submitters the purposes of 1reporting
submit Leg under
information EMIR
in the firstRTS 2.0swap stream block and Leg 2 information in the second FpML swap stream
FpML
block
Note 1: Where 'higher spread' is used to determine the Buyer / Seller, the higher value is to apply, i.e. if the spreads were '-0.1' and '-0.5', the the higher spread would be '-0.1'.
Note 2: Where the below table fails to determine Buyer then use the tiebreaker logic of Reverse ASCII Sort, first LEI. For the avoidance of doubt, the order is Z, Y, X, W, V, U, T, S, R, Q, P, O, N, M, L, K, J, I, H, G, F,
E, D, C, B, A, 9, 8, 7, 6, 5, 4, 3, 2, 1, 0. The party whose LEI starts with the first value found in the list will be the Payer of Leg 1
Asset Class Base Product Sub- Transaction Type Leg 1 / Leg 2 Proposal Buyer (for Counterparty Side) Seller (for Counterparty Side) Article 3a point Comments
Product
Interest Rate IR Swap Fixed Float Leg 1 = Fixed Leg Payer of Fixed Rate Receiver of Fixed Rate 5
Leg 2 = Float leg
Interest Rate IR Swap Fixed Float OIS As IR Swap Fixed/Float Payer of Fixed Rate Receiver of Fixed Rate 5
Interest Rate IR Swap Fixed Float Zero Coupon As IR Swap Fixed/Float Payer of Fixed Rate Receiver of Fixed Rate 5
Interest Rate IR Swap Fixed Fixed Leg 1 = Higher Fixed Rate Payer of Leg 1 Receiver of Leg 1 5 For example, if both legs have the same Rate,
Leg 2 = Lower Fixed Rate but one leg of the swap has a 3 month
calculation period and the other leg has a 6
If both legs have the same Rate, then: month calculation period, the 3 month period
Leg 1 = Leg with the shortest calculation period will trump the 6 month period. Therefore, Leg
1 would be the leg with the 3 month
calculation period.
'Calculation Period' rather than 'Reset Period'
is used as a Fixed Rate would not be expected
to reset each period.
Interest Rate IR Swap Basis Leg 1 = Leg with the higher spread Payer of Leg 1 Receiver of Leg 1 5 See example under IR Swap Fixed Fixed.
If both legs have the same spread, then:
Leg 1 = Leg with the shortest reset period
Interest Rate IR Swap Basis OIS As IR Swap Basis Payer of Leg 1 Receiver of Leg 1 5
Interest Rate Cross Currency Fixed Float Leg 1 = The currency which appears first when Party receiving (ie paying interest on) the currency which appears Party delivering (ie receiving interest on) the currency which 6 As per ITS Article 3a, paragraph 6, the Buyer
sorted alphabetically by ISO 4217 standard. first when sorted alphabetically by ISO 4217 standard appears first when sorted alphabetically by ISO 4217 standard and Seller for cross currency swaps are to be
determined by ordering the currencies
alphabetically. The Buyer shall be the
counterparty receiving the currency which
appears first, and the Seller shall be the
counterparty delivering the currency which
appears first.
The Leg Alignment best practice is based on
the Buyer/Seller determination, with Leg 1
being the leg of the first currency when sorted
alphabetically, and Leg 2 being the second
currency.
Interest Rate Cross Currency Fixed Fixed Leg 1 = The currency which appears first when Party receiving (ie paying interest on) the currency which appears Party delivering (ie receiving interest on) the currency which 6 As per ITS Article 3a, paragraph 6, the Buyer
sorted alphabetically by ISO 4217 standard. first when sorted alphabetically by ISO 4217 standard appears first when sorted alphabetically by ISO 4217 standard and Seller for cross currency swaps are to be
determined by ordering the currencies
alphabetically. The Buyer shall be the
counterparty receiving the currency which
appears first, and the Seller shall be the
counterparty delivering the currency which
appears first.
The Leg Alignment best practice is based on
the Buyer/Seller determination, with Leg 1
being the leg of the first currency when sorted
alphabetically, and Leg 2 being the second
currency.
Interest Rate Cross Currency Basis Leg 1 = The currency which appears first when Party receiving (ie paying interest on) the currency which appears Party delivering (ie receiving interest on) the currency which 6 As per ITS Article 3a, paragraph 6, the Buyer
sorted alphabetically by ISO 4217 standard. first when sorted alphabetically by ISO 4217 standard appears first when sorted alphabetically by ISO 4217 standard and Seller for cross currency swaps are to be
determined by ordering the currencies
alphabetically. The Buyer shall be the
counterparty receiving the currency which
appears first, and the Seller shall be the
counterparty delivering the currency which
appears first.
The Leg Alignment best practice is based on
the Buyer/Seller determination, with Leg 1
being the leg of the first currency when sorted
alphabetically, and Leg 2 being the second
currency.
Interest Rate Exotic If there is no obvioulsy Buyer/Seller, then: Buyer = Party whose LEI is found first through Tiebreaker Logic Seller = Party whose LEI is found second through Tiebreaker Logic NA Note: It is acepted that the LEI tiebreaker logic
Leg 1 = leg paid by Buyer is not ideal, but for trades where there is an
absense of an obvious Buyer / Seller,
tiebreaker logic is felt to be the best option
available.
Interest Rate Inflation (1) Fixed vx Float then as per IR Swap Fixed/float 1) Payer of Fixed Rate 1) Receiver of Fixed Rate 5
(2) Float vs Float then as per IR Swap Basis 2) See IR Swap Basis 2) See IR Swap Basis
Interest Rate Option Swaption As per the 'Leg 1 / Leg 2 Proposal' applicable to Party who holds the right to exercise the option Receiver of Premium 2
the product type of the underlying swap
Interest Rate Inflation CapFloor N/A Party who holds the right to exercise the option. Receiver of Premium 2 As per RTS Article 3a, paragraph 2, Leg
Alignment for options and swaptions, the
Buyer is identified as the party that holds the
right to exercise and the Seller is the reciever
of premium.
Interest Rate Option Debt Option N/A Party who holds the right to exercise the option Receiver of Premium 2
Interest Rate Forward Debt N/A Buyer of the instrument Seller of the instrument 3
Interest Rate FRA N/A Payer of Fixed Rate Receiver of Fixed Rate 10
Interest Rate CapFloor N/A Party who holds the right to exercise the option Receiver of Premium 2 As per RTS Article 3a, paragraph 2, Leg
Alignment for options and swaptions, the
Buyer is identified as the party that holds the
right to exercise and the Seller is the reciever
of premium.
Article 3a
Counterparty side
1. The counterparty side to the derivative contract referred to in field 14 of Table 1 of the Annex shall be determined in ac
paragraphs 2 to 10.
2. In the case of options and swaptions, the counterparty that holds the right to exercise the option shall be identified as th
counterparty that sells the option and receives a premium shall be identified as the seller.
3. In the case of futures and forwards other than futures and forwards relating to currencies, the counterparty buying the
identified as the buyer and the counterparty selling the instrument shall be identified as the seller.
4. In the case of swaps related to securities, the counterparty that bears the risk of price movement of the underlying secu
the security amount shall be identified as the buyer and the counterparty that pays the security amount shall be identified
5. In the case of swaps related to interest rates or inflation indices, the counterparty paying the fixed rate shall be identifie
the counterparty receiving the fixed rate shall be identified as the seller. In the case of basis swaps, the counterparty that p
shall be identified as the buyer and the counterparty that receives the spread shall be identified as the seller.
6. In the case of cross-currency swaps and swaps and forwards related to currencies, the counterparty receiving the curren
first when sorted alphabetically by International Organization for Standardization (ISO 4217) standard shall be identified as
counterparty delivering that currency shall be identified as the seller.
7. In the case of swaps related to dividends, the counterparty receiving the equivalent actual dividend payments shall be id
buyer and the counterparty paying the dividend and receiving the fixed rate shall be identified as the seller.
8. With the exception of options and swaptions, in the case of derivative instruments for the transfer of credit risk, the cou
the protection shall be identified as the buyer and the counterparty selling the protection shall be identified as the seller.
9. In the case of derivative contracts relating to commodities, the counterparty that receives the commodity specified in th
identified as the buyer and the counterparty that delivers the commodity shall be identified as the seller.
10. In the case of forward-rate agreements, the counterparty paying the fixed rate shall be identified as the buyer and the
receiving the fixed rate shall be identified as the seller.