ESMA published updated EMIR Refit Guidelines

On 23 Oct 2023 ESMA published an updated version of EMIR Refit guidelines.
The Guidelines are available here.

The mistakes in the examples have been corrected by ESMA.


ESMA published revised EMIR Refit validation rules and XML EMIR Reporting Schemas

On 6 Sept ESMA published revised EMIR Refit Validation Rules applicable from 29 April 2024.

All changes are marked with red colour. The revised validation rules are available here.

The revised XML EMIR Reporting Schemas for incoming and outgoing messages are available here.

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ANNA DSB publishes UPI Fee Model Variables and Annual User Fee Update

ANNA DSB published today the Unique Product Identifier (UPI) Fee Model Variables and Annual User Fees for 2023 and 2024. The UPI Service will be launched on 16 October 2023 in production.

The UPI Fee Model Variables and Annual User Fee Update provide details on the latest financial forecast for the UPI Forecast Total DSB Cost and the estimate user numbers for the UPI Service. UPI Annual User Fee details are also available on the UPI Fees & Rules page of the DSB website.


UnaVista change to CFI code validation rule – EMIR

On 9th Sept, 2023 UnaVista will implement changes to CFI code validation rule.

The impacted field is Instrument Classification – CFI Code.

From 9th Sept, 2023 UnaVista will verify that a valid CFI code is being reported under EMIR. The CFI code reported should be valid as per the ISO 10962 standard, CFI Code current list maintained by SIX.

As per UnaVista’s notification: Submissions that fail the validation will get the message ‘Instrument Classification must be a valid CFI if Instrument Classification Type specifies C’.

Additional Details

  • The validation checks all six letters of the CFI code to ensure that it is a valid code. Hence codes such as FFXXXX or JFXXXX will no longer be accepted.
  • Not all CFI codes from the list previously published in 2015 are valid as per the current list. Example codes such as SRACSC & HFRAVC which were valid previously are no longer valid.
  • CFI Code list (maintained by SIX) can be accessed via their website here.

We would encourage all clients of UnaVista to perform tests on their UAT environment.


UAT Start: 30th June 2023
UAT End: 25th August 2023
Production Release Date: 9th September 2023

For more information, please feel free to contact us at or go to UnaVista Customer Portal.


FCA published final UK EMIR Validation Rules and XML schemas

On 26 April 2023 FCA published final UK EMIR Validation Rules and XML schemas to support implementation:

For more information please click here.



EMIR Refit field UPI – ANNA DSB published OTC ISIN JSON

With regards to EMIR REFIT and new field UPI (unique product identifier) we would like to inform you that ANNA DSB has officially published OTC ISIN JSON templates with UPI code.

The UPI UAT and other services will be published by 8th of March 2023.

For further details please visit:

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ESMA publishes Guidelines and Technical documentation XML schema on EMIR Refit

ESMA is clarifying the legal provisions on reporting and data management under the amended EMIR rules and providing practical guidance on their implementation.

The Guidelines published today will further enhance the harmonisation and standardisation of reporting under EMIR contributing to the high quality of data necessary for the effective monitoring of the systemic risk. Furthermore, increased harmonisation and standardisation of reporting allows to contain the costs along the complete reporting chain – the counterparties that report the data, the TRs which put in place the procedures to verify the completeness and correctness of data, and the authorities, defined in Article 81(3) of EMIR, which use data for supervisory and regulatory purposes. The Guidelines provide clarifications on the following aspects:

  • transition to reporting under the new rules,
  • the number of reportable derivatives,
  • intragroup derivatives exemption from reporting,
  • delegation of reporting and allocation of responsibility for reporting,
  • reporting logic and the population of reporting fields,
  • reporting of different types of derivatives,
  • ensuring data quality by the counterparties and the TRs,
  • construction of the Trade State Report and reconciliation of derivatives by the TRs,
  • data access.

The final report on Guidelines, published today is accompanied by the validation rules and the reporting instructions (here and here), i.e. XML schemas.

The validation rules document sets out detailed technical rules on how the TRs should verify the completeness and accuracy of the reported data as well as the conditions and thresholds to be applied to determine whether the values reported by both counterparties match or not. Finally, the Validation rules document contains also a template for notifications of reporting errors and omissions to the NCAs.

The reporting instructions contain EMIR XML messages which were updated or newly developed based on the revised technical standards and validation rules. A fully standardised format for reporting will eliminate the risk of discrepancies due to inconsistent data. End-to-end reporting in ISO 20022 XML is expected to further enhance data quality and consistency and mitigate the data integrity risks, by reducing the need for data cleaning/normalisation and facilitate their exploitation for various supervisory and/or economic analysis based on the changes presented by the EMIR Refit regulation. The implemented schema sets were designed to ensure the backward compatibility of the data reporting.

Next steps

The final report contains a detailed assessment of the feedback received to the proposals in the consultation paper published in July 2021. ESMA will continue to engage with the market participants with a view to clarifying any remaining doubts and to facilitate a smooth transition to reporting under EMIR REFIT. The guidelines will be translated and published in all EU languages. They will enter into application on 29 April 2024.

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EMIR REFIT ISO 20022 XML from 29 April 2024

EU EMIR REFIT regulatory technical standards (RTS) and implementing technical standards (ITS) have been published in the Official Journal of the European Union on 7 Oct 2022.

EMIR REFIT ISO 20022 XML apply from 29 April 2024.

Key changes:

  • Reports submitted to an EU TR must comply with the ISO 20022 XML message standard;
  • Responses from the EU TR to submissions must comply with the ISO 20022 XML message standard;
  • Unique Product Identifier (UPI) is introduced;
  • Unique Trade Identifier (UTI) should be generated in accordance with ISO 23897 Unique Transaction Identifier;
  • The number of collateral fields is increased. The overall number of fields is increased to 203;
  • The entity responsible for reporting shall promptly notify NCA of the reporting counterparty of any misreporting, significant issues, etc.

This is a non-exhaustive list.

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ESMA updates Q&As on EMIR implementation

On 21st Nov, 2021 ESMA has published updated Q&As on EMIR implementation.

The amendments include:

  • calculation of the clearing threshold;
  • hedging definition.

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ESMA launched a public consultation on its draft Guidelines for EMIR REFIT

The European Securities and Markets Authority (ESMA), the EU’s securities markets regulator, has today launched a public consultation on its draft Guidelines for derivatives reporting under EMIR – EMIR REFIT.

The Consultation Paper (CP) includes draft Guidelines on a wide range of topics related to reporting, data quality and data access under EMIR Refit. ESMA has also published validation rules that clarify dependencies between data fields, as well as their applicability in the different use cases.

The Consultation paper focuses on:

  • how reports should be constructed and in what circumstances reports should be made;
  • reporting logic, including the use of action and event types;
  • reporting in the case of delegation as well as under provisions on allocation of responsibility for reporting;
  • the population of specific sections of fields; and
  • the correct population of fields for different reporting scenarios and different products.

The Draft Guidelines also clarify important aspects of the procedures to be implemented by reporting entities and Trade Repositories to enhance data quality. The paper also clarifies certain operational aspects concerning data access.

The proposed Guidelines, together with the validation rules, complement the revised draft EMIR technical standards on reporting by counterparties, data quality and data access. These standards were submitted to the European Commission on 16 December 2020 and, for the first time under EMIR, mandated the end-to-end use of ISO 20022 XML messages.

ESMA’s proposals aim to facilitate compliance and ensure consistent implementation of the EMIR reporting rules.

Next Steps

The closing date for responses is 30 September 2021. ESMA will consider the responses to this consultation with a view to finalising the proposed Guidelines and will publish a final report in Q4 2021/Q1 2022 (subject to the adoption of the draft RTS and ITS on reporting by the European Commission).

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