ESMA have this evening published the latest Questions and Answers document only hours before the reporting deadline. Amongst the new answers (with items that may be of particular interest in bold):

• If an NFC notified that they were an NFC+, but it later turns out that this was not the case, based on new assumptions, the NFC+ obligations are lowered retrospectively.
• Mark to Market and Collateral information does not have to be backloaded from 12th August for NFC+/FCs.
• Every party to a trade must be identified. If a third party does not permit such identification, then the EU based party will be in breach of EMIR.
• In the absence of a UPI, the interim taxonomy (“E”) should be used. Counterparties must agree between them what to use.
• UTIs may be less than 52 characters long
• UTIs should if possible be constructed using one of 4 methods, and prefixed with E01-E04 to show which. In outline the method is to concatenate the LEI/MIC of the issuing party and then a unique code. See page 62 for details.
• The UTI should be generated by the highest in the hierarchy: 1)Venue,2)FC, 3)NFC+, 4)Seller
• Missing fields  – Non Mandatory should be blank, missing information should be set to “NA”.
• Talk about complex contracts but nothing about multi legged commodity trades

Market participants still have several hours to conform.