On February 16, 2022, ISDA responded to the joint Bank of England and Financial Conduct Authority consultation on changes to reporting requirements, procedures for data quality and registration of trade repositories under the UK implementation of the European Market Infrastructure Regulation (EMIR). The consultation sets out proposals for aligning the UK’s derivatives reporting framework with international guidance from the Committee on Payments and Market Infrastructures and International Organization of Securities Commissions. It also covers measures for mandatory delegated reporting requirements, counterparty notifications and reconciliations processes, and the use of XML schemas and global identifiers.

In the response, ISDA highlights several observations and suggestions on topics including the use of identifier codes, report formats, mandatory delegated reporting requirements, unique trade identifiers and the reporting of exchange-traded derivatives as over-the-counter trades.