The first phase of REMIT reporting, due to start on 7th October, requires Market Participants to report orders and trade related to activity on Organised Market Places (OMPs). Since OMPs are obligated to “offer a data reporting agreement” to Market Participants, many have assumed that this phase will be simple, since reporting can be outsourced.

This latest article on the ICIS website highlights one of the issues associated with this, which is that of fragmentation, that it is not always clear where the data is, and how to link it together. The article has quotes from both Trayport and EFETNet about how they are trying to solve this issue, both separately(see also here and here) and together.

There are also other issues that could prevent a Market Participant from relying on OMPs to report, namely:

• Venues do not have all of the data to report – Fields such a beneficiary ID, link ID and others are not known by the venue, so this must either be provided to them, or reported another way.
• Some venues (i.e. broker platforms) do not get involved in post trade events, such as modifications and early terminations. These must be reported separately, which will be complex if the venue is reporting the original execution.

In effect, this means that for most Market Participants, there will be plenty of work to do for the first phase of reporting as well as the second.