EMIR Refit: FCs Reporting on Behalf of Both Itself and NFC- Clients: Operational Considerations

Following the publication of EMIR Refit, as of June 18, 2020, financial counterparties (FCs) will be legally liable for the timely and accurate reporting of over-the-counter (OTC) derivatives contracts on behalf of both themselves and their non-financial counterparty minus (NFC-) clients. This requirement raises several operational challenges and points to be considered by both FC and NFC- entities.

This document captures some of these operational considerations and potential steps FCs and NFCs may need to take (as identified by the ISDA Data and Reporting EMEA Working Group) in order to adhere to this EMIR Refit requirement.

Documents (1) for EMIR Refit: FCs Reporting on Behalf of Both Itself and NFC- Clients: Operational Considerations

Creating Value - IQ June 2025

Ever since its establishment 40 years ago, ISDA has worked to enhance the safety and efficiency of derivatives markets. That has motivated everything we do – from the development of standard documentation and the rollout of new digital solutions to...

Paper on EC’s Sustainability Omnibus Proposal

On June 9, ISDA published a position paper setting out its views on the European Commission’s (EC) Sustainability Omnibus Package. In the paper, ISDA urges European authorities to: Ensure a proportionate, harmonized and symmetrical approach to the use of derivatives...

Bulk Adherence Upload Page

Please download the attached Excel worksheet and fill out a separate row for each adherence. Then select and upload your completed file using the buttons below. If any errors are found, please correct and re-upload. Please allow the process time...