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.