The Futures Industry Association has issued this paper on the topic of reporting Exchange Traded Derivatives (ETD) under EMIR. The paper proposes some changes to simplify position reporting of ETDs.

Unlike other reporting regimes around the world, EMIR requires that ETDs be reported by market participants. Many of those who report prefer to do so on a position basis. Holding a position in a Trade Repository makes it easier to submit valuation and collateral updates around the ETD. However, those who wish to maintain positions in a Trade Repository are currently required to observe a complex multi step process, requiring that the underlying trades comprising the position  be sent in a separate channel as well as the position. The paper recommends that the complexity be reduced and only positions sent.

Many in energy and commodities attract “NFC-” status under EMIR, removing the requirement to submit valuation and collateral updates. As a result many only send ETDs as trades.