ESMA have updated the Questions and Answers document on EMIR reporting, which can be found here. There is one new answer (TR 43 on page 95), in two parts, which relate to the reporting of cleared trades:
- The CCP ID field may only contain the ID of an approved CCP and not another clearer.
- If a transaction is executed in an anonymised market and cleared, the venue or clearer must reveal the counterparty by the reporting deadline so that both parties to the trade may be reported.
It will be interesting to see how the second answer is implemented.