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.

For more information please feel free to contact us back at