On 30 September 2021, ISDA submitted a response to the European Securities and Markets Authority’s (ESMA) Consultation Paper on the Guidelines on reporting under EMIR. Two response documents were submitted: one provides responses to the questions put forward by ESMA and the second document provides comments on the validation and reconciliation rules. In the response, ISDA highlighted a several points including:
The application of field reconciliation and tolerance levels
The use of UPIs and related reference data
The format of TR reports
ETDs being reported as OTC derivatives when executed on third country markets
ESMA intend to publish a final report on the EMIR reporting guidance in the first quarter of 2022 based on the response received for this consultation.