ESMA has recently updated its Q&A tool, making it interactive and searchable.
To help make finding answers to EMIR REFIT questions as efficient as possible, we've curated relevant questions and answers, making them easy to find in a table below.
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We'll continue to update the table as and when new questions and answers are made available.
| Topic | Link | Question | CN Subject Matter | Status |
| EMIR Reporting | ESMA_QA_2092 | Guidelines on reporting under EMIR REFIT clarify that under Collateralise-to-Market model (CTM) the counterparties should report total variation margin and total collateral, whereas under the Settle-to-Market model the counterparties should report the daily change in the variation margin and the collateral. In which field counterparties should report whether the portfolio of cleared derivatives is collateralised under CTM or STM model? | Reporting under STM/CTM model | Answer published |
| EMIR Reporting | ESMA_QA_2202 | (a) For the purpose of reporting under EMIR REFIT, how should OTC accumulator contracts – i.e., derivative contracts in which the buyer enters into an agreement to purchasing a predetermined number of underlying financial instruments at a predefined price, per day - over a specified ‘accumulation’ period, be classified? (b) How should these contracts be reported under EMIR REFIT? | Accumulator contracts | Answer published |
| EMIR Reporting | ESMA_QA_2203 | Should the price field at position level be amended following a change in the notional amount? | Reporting of price field at position level | Answer published |
| EMIR Reporting | ESMA_QA_2094 | How should a counterparty falling within scope of Article 1(4)(a) and (b) of Regulation (EU) No 648/2012 be reported under Field 11 of Table 1 of the RTS on reporting under EMIR REFIT, ‘Nature of Counterparty 2’? | Reporting of a Counterparty | Question published |
| EMIR Reporting | ESMA_QA_1461 | Paragraph 558 of the Guidelines (p.289) clarifies that ‘TRs should update the TSR based on the latest information for a given derivative as derived from the field ‘Event date’. Use case 4 in the Guidelines (p. 291) further illustrates that in the case of late reporting of historic events, the relevant information should be updated in the TR’s database only until the Event date of the subsequent event to avoid overwriting the information from more recent reports. In this context, how should counterparties report historic corrections on outstanding derivatives that were not yet upgraded after EMIR Refit go-live (and thus no Event Date was previously reported for those derivatives)? How should trade repositories consider the sequencing of submissions to determine the validity of historic corrections? | Reporting of Corrections of Transactions with no Event Date | Question published |
| EMIR Reporting | ESMA_QA_2093 | Are the reporting counterparties and entities responsible for reporting expected to update during the transition period any client codes not compliant with the requirements set out under EMIR REFIT? | Update of the client codes | Question published |
| Other issues (CCP) | ESMA_QA_924 | How should the mark-to-market value of contracts for difference that are not cleared by a CCP be reported in accordance with Regulation (EU) No 648/2012 and standard 13 of the international financial reporting standards? | Reporting of MTM value of CFDs | Awaiting answer |