On 1st November 2017 the fields and formats with which trades must be reported under EMIR will change (see here). This is the third set of changes to be made since reporting originally went live on 12th February 2014, and is therefore referred to by some as “Level 3 validations”, following the naming convention of the previous iterations. The changes however are more significant than previous ones, since many new fields are being added. In addition, new codes such as CFIs and LEIs will become mandatory.

This article by Shuchika Kohli and Ananya Mohata of  Sapient Global Markets on the Tabb Forum web site looks at the types of changes required. It argues that those who have so far followed a tactical approach in meeting different reporting regulations on a piecemeal basis may now wish to consider a more strategic approach, especially in the light of new regulations in the pipeline such as MiFID II, as well as ongoing changes to existing rules, which in the energy and commodities sector will likely include REMIT.

This article by Lloyd Altman of Regtek Solutions in the Journal of Securities Operations & Custody also examines the challenge of meeting multiple regulatory reporting requirements which undergo regulatory changes.

The changes to EMIR will continue when the changes proposed under the EMIR Review are implemented, likely in just over 18 months’ time. These change what needs to be reported, by whom and how (see here). Many non financial counterparties will likely have preferred that the two sets of modifications are packaged together, as in some cases the scope will decrease with the second set of changes.