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.