ESMA has updated the EMIR Questions and Answer document, which can be found here. The main update is on page 95, and refers to the transition to the new EMIR RTS, which starts on 1st November 2017. The Q+A makes several points:

• Existing contracts – there is no need to re report already submitted trades after 1st November, unless there is a reportable event, such as a modification. In that case, the events must be sent using the new format.
• Validations – From 1st November the new validation rules must be used, including to events such as valuation updates, even relating to existing trades.
• Complex trades – The new RTS permits complex trades to be linked together over several UTIs. However trades already reported using one UTI do not need to be re reported.
• Expired trades – do not need to be re reported, unless an error is identified, in which case the new format should be used.

Given that any change at all after 1st November will need to use the new format, market participants are likely to require some planning to effectively manage the transition.  It may also lead to some changes in TR for some market participants,. ESMA opened a new consultation on the topic this week. This article on RegTechFS  looks at some of the other aspects of the transition.