ESMA has today updated its EMIR Q&A which includes 1 new topic;
Q&A TR54: Reporting by a financial counterparty (FC) on behalf of a non-financial counterparty below clearing threshold (NFC-) under EMIR Refit.
In particular, the TR Q&A TR54 clarifies:
What are the reportable details that the NFC- should provide to the FC;
how the FC should proceed if the NFC- does not renew its LEI;
how the FC should proceed if an NFC that has been classified as an NFC+ changes its status to NFC- and fails to timely inform the FC of this fact;
how FC and NFC- should proceed if they report to two different trade repositories.