Don’t Struggle with EMIR Reporting – Use This Best Practise Guide
Although EMIR reporting started in 2014 the data quality has needed continuous improvement. Now the International Swaps and Derivatives Association, Inc. (ISDA), the European Fund and Asset Management Association (EFAMA), the European Venues and Intermediaries Association (EVIA), the Futures Industry Association (FIA) and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association (GFMA) have publishing a public field-by-field best practise guide.
For the record I was responsible (along with a smart team) to prepare a large clearing house for EMIR reporting in 2014. Amongst the many challenges were interpreting the field level rules for how to report data items, and in context how they represented both OTC and ETD trades.
Much work has taken place since, and now a new set of guidelines exists for all to use. The guide covers a wide set of data items for which it was felt a best practise steer would improve data quality. The guide is expressed as an Excel spreadsheet with multiple tabs covering 87 data items for 61 reportable fields.
The guide is specific to EU and EMIR even if some of the ideas are applicable to other jurisdictions. Many people from the trade organisations worked to produce this best practise guide, and are providing it fully publicly for all to use.
From the press release
The EMIR Reporting Best Practices cover 87 data points across 61 reporting fields, including both over-the-counter and exchange-traded derivatives, and were developed to improve the accuracy and efficiency of trade reporting and to reduce compliance costs. The best practices are available to all market participants to access and implement.
Mandatory trade reporting under EMIR came into force in 2014, requiring all covered derivatives to be reported to trade repositories separately by both parties. However, differences in how each counterparty completes the data fields can lead to matching errors on individual trades, placing a compliance burden on industry participants and resulting in an unclear picture of trading activity and risk. In February 2019, the European Securities and Markets Authority estimated the matching rate to be just 40%.
The EMIR Reporting Best Practices aims to facilitate greater standardization in how firms complete certain data fields when reporting under EMIR. The document sets out best practice standards for those reporting fields that are most commonly mismatched, based on feedback from trade repositories, but other fields may be added over time if required.