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No UPI in ANNA DSB for a certain CFI code?

For cleared transactions executed on non-EEA venues, you might not be able to find any UPIs in ANNA DSB database by searching certain CFI codes. The reason is that ANNA DSB will not issue any UPI for listed products.

The lack of UPI if the venue of execution is outside the EEA (i.e., the venue of execution is not in the list of regulated markets, MTFs or OTFs) was a reason for a rejection.

Two days before the EMIR Refit go-live date the trade repositories have relaxed the rules for using UPIs.

You may populate only field Underlying identification (with tag <UndrlygInstrm> <ISIN>) and your record will be approved without UPI.

If there is UPI with the relevant CFI code in ANNA DSB, always make sure you use it.

Always make sure that the CFI code you are using is the correct one.


ESMA updated EMIR Q&As

On 2 February 2024 ESMA has updated Q&As on implementation of EMIR as well as provided answers to the following questions.

ETDs Reporting Question

Scenario 1 in the answer to ETDs Reporting Question 2 (“Which parties have to report ETD contracts?”) has been updated in order to show that the Broker ID field should no longer be populated for point 4 and point 5 of the table (on p. 141 of the document).

Reporting under STM/CTM model

Question: Guidelines on reporting under EMIR REFIT clarify that under Collateralise-to-Market model (CTM) the counterparties should report total variation margin and total collateral, whereas under the Settle-to-Market model the counterparties should report the daily change in the variation margin and the collateral. In which field counterparties should report whether the portfolio of cleared derivatives is collateralised under CTM or STM model?

Answer: There is no separate field to report which model has been used for a given portfolio. In order to ensure that data users can interpret correctly the reported values, the counterparties should indicate it as part of the collateral portfolio name by using prefix ‘STM’ where the Settle-to-Market model is used. For example, if currently a portfolio code reported for a given portfolio is 12345ABCDE, under EMIR REFIT the code could be updated to STM12345ABCDE.

Update of the client codes

Question: Are the reporting counterparties and entities responsible for reporting expected to update during the transition period any client codes not compliant with the requirements set out under EMIR REFIT?

Answer: Yes, counterparties and entities responsible for reporting are expected to update all fields (except for UTIs) at the latest by the end of the 180-day transition period, or earlier whenever a relevant lifecycle event needs to be reported. Given that the modification of a client code once it has been reported is not allowed, the counterparties and entities responsible for reporting should apply in this case the procedure for the update of the identifier set out in the Article 8 of the ITS on reporting and described in the ‘Procedure when a counterparty undergoes a corporate action’ Section in the Guidelines. TRs may reach proactively to their clients to coordinate and facilitate update of the client codes. It should be noted that the procedure for update of client codes concerns only outstanding derivatives. If counterparties need to revive a derivative with a legacy client code, they should do so (it is allowed under the validation rules) and subsequently request the TR to update the client code in line with the procedure.
Reporting of a Counterparty falling within scope of Article 1(4)(a) and (b).

Reporting of a Counterparty falling within scope of Article 1(4)(a) and (b)

Question: How should a counterparty falling within scope of Article 1(4)(a) and (b) of Regulation (EU) No 648/2012 be reported under Field 11 of Table 1 of the RTS on reporting under EMIR REFIT, ‘Nature of Counterparty 2’?

Answer: In the eventuality that a counterparty falling within scope of Article 1(4)(a) and (b) of EMIR is identified as the ‘Other Counterparty’, they should be classified as ‘Other’ in Field 11 of Table 1 of the RTS on reporting under EMIR REFIT, ‘Nature of Counterparty 2’.

Portability of Schedules

Question: As clarified in the Guidelines on transfer of data between Trade Repositories under EMIR and SFTR , in the case of transfer of data requested by a TR participant the TRs should transfer only the latest state of the outstanding derivatives (‘Trade State Report’, TSR). Are the TRs expected to follow this guideline with regards to the notional schedules, given that the TSR will not contain the full schedules (for the notional quantity, amount etc.) but only the currently applicable value?

Answer: Yes, TRs should follow the Guidelines on transfer of data also with regards to the schedule information and port only the TSR which does not include the entire schedule information.
To ensure accurate representation of the schedule values in the TSR generated by the new TR, a counterparty should report to the new TR a modification containing the complete schedule information which will enable the new TR to update the TSR with the relevant values.


Question: Table 102 of the Guidelines specifies that GLEIF database should be used to determine the access rights of the relevant members of the ESCB, including the ECB in carrying out its tasks within a single supervisory mechanism, when applying the filtering for the fields 2.144 ‘Reference entity’, 1.4 ‘Counterparty 1 (Reporting counterparty’, 1.9 ‘Counterparty 2’, 1.15 ‘Broker ID’ and 1.16 ‘Clearing member’. Should the authorities in question have also access to the derivatives involving subsidiaries of the relevant entities and, if so, how the access rights should be determined?

Answer: Yes, the members of ESCB, as well as any other authority covered under Article 2(11) and 2(13) of RTS 151/2013, should have access to transaction data on derivatives in which the subsidiaries of the entities falling under their supervision are involved. To determine whether an entity is a subsidiary of a supervised entity, the trade repositories should use the relationship data (so called Level 2 data) in GLEIF database.

For information regarding the updated Questions and Answers for Credit Rating Agencies (CRA) Regulation, Markets in Crypto Assets (MiCA) and Markets in Financial Instruments Regulation (MiFIR) Regulation, please refer to the News section here.


KDPW-TR launched the EU EMIR Refit test environment

On 12th Dec KDPW-TR launched the EU EMIR Refit test environment – KDPW_TR EMIR REFIT (TST REFIT).

The testing can be done by both the GUI and via the A2A channel through dedicated queues. Currently test messages containing only Action Type NEWT and POSC can be submitted. As soon as the other ‘Action Types’ are available, KDPW-TR will inform its clients accordingly.

KDPW-TR will maintain EMIR (TST environment in line with the current RTS) along with EMIR-REFIT test environment in line with RTS effective from 29th April 2024.

Currently, in EMIR REFIT TST, only a part of the functionality is available, primarily related to reporting transactions to KDPW_TR. The remaining functionalities will be available at a later date. End-of-day reports will be generated in TST REFIT from the end of January 2024. As for reporting with dedicated queues, new connection parameters are available in the “MQ Connection Parameters” document in the “A2A Certificates” application.


Updated XML EMIR Reporting Schemas

On 27 November 2023 ESMA published updated XML EMIR Reporting Schemas:

For more information please feel free to contact us at


LSEG Post Trade launched EU EMIR UAT

On 31 October 2023 LSEG Post Trade launched EU EMIR UAT Phase I. The release focuses on file submission and validation rules, allowing clients to validate the accuracy and correctness of the EMIR reports.

The scope of the release comprises:

  • User Interface – file load summary showing the status of the files loaded. All Exceptions folder showing all rejected reports alongside the rejection reason and the “All Valid Transaction” folder showing all records accepted by EU EMIR Trade Repository.
  • Validation Rules – technical validation confirming the compliance with ISO20022 XML. Business Rules validating that the various interdependencies between the fields have been considered. Logical validation confirming that the lifecycle sequence is permitted.

On 18 December 2023 EU EMIR UAT Phase II will be released. The release will focus on the validation response files and remediation of client identified defects.

Validation Response – ISO20022 XML response message confirming the acceptance or rejection of your EMIR reports.

On 31st January 2023 Phase III release will be launched. It will include any deferred functionality.

We at EMIR Reporting Ready, Ltd. are already successfully testing EMIR REFIT ISO20022 XML reports. If you have an account with LSEG Post Trade (formerly known as UnaVista), we can provide you with approved customized templates designed especially for your organization, financial instruments, counterparties and transaction chain. We can boost your EMIR Refit readiness by answering all your questions. Or you can take advantage of our turn-key solutions.

For more information, please contact us at


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.

For more information, please feel free to contact us back at


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.