On 6th September 2023 ESMA has published its EMIR REFIT validation rules.
Here is a detailed recap of the changes.
Changes to the Revised ESMA EMIR REFIT
Validations General Information
A clarification has been added concerning conditional values depending on fields that are not present in the submitted report. They should be performed based on the last accepted report, with such validations being performed only when Event Date is T or T-1.
| Field ID | Field Name | Change type | Conditions/Format & Content | Error Code |
| 1.3 | Entity responsible for reporting | Added new condition to existing validation | Clarified that field should be blank if specified conditions not met | N/a |
| 1.9 | Counterparty 2 | Minor correction | Corrected numbering in the file, removed redundant validation code. Content was not changed | EMIR-VR-1009-09 |
| 1.16 | Clearing member | New validation | Validation added: Clearing member cannot be a registered CCP | EMIR-VR-1016-07 |
| 2.2 | Report tracking number | Minor correction and new validation | Minor clarification added in point 2 Validation added: field to be left blank for position reports | EMIR-VR-2002-04 |
| 2.4 | Subsequent position ID | Minor correction | Clarification that validations apply to relevant action types | EMIR-VR-2004-03 EMIR-VR-2004-04 |
| 2.5 | PTRR ID | Minor correction | Clarification to leave field ‘PTTR ID’ blank when ‘Type of PTRR technique’ is not populated Clarification that validations apply to relevant action types | EMIR-VR-2005-02 EMIR-VR-2005-03 EMIR-VR-2005-04 |
| 2.7 | ISIN | Added new condition to existing validation | Clarification added for ISIN to be optional for executions with SIs | EMIR-VR-2007-01 |
| 2.27 | Collateral portfolio code | Field population condition | Field changed from not applicable to conditional for correction on a position report | N/a |
| 2.38 | PTRR | New validation | Validation added: PTRR should be left blank for position reports | EMIR-VR-2038-02 |
| 2.4 | PTRR service provider | New validation | Validation added: PTRR should be left blank for Portfolio Compression without a third-party service provider | EMIR-VR-2040-04 |
| 2.41 | Venue of execution | Field population condition | Field changed from optional to mandatory for correction on a position report. | N/a |
| 2.42 | Execution timestamp | New validation | Validation added: Execution timestamp cannot be changed for modification reports | EMIR -VR-2042-03 |
| 2.44 | Expiration date | New validation Minor correction | Validation added: expiration date should be the same or later than ‘Reporting timestamp’ for derivative reports re-opened (revived) after mistaken termination Minor clarification – previously existing validation number shifted to EMIR-VR-2044-05 as the new validation is added as EMIR-VR-2044-04 | EMIR-VR-2044-04 EMIR-VR-2044-05 |
| 2.45 | Early termination date | New validation | Validation added: ‘Early termination date’ should be left blank for derivative reports re-opened (revived) after mistaken termination | EMIR-VR-2045-08 |
| 2.48 | Price | Minor correction | Population of field ‘Price’ for commodity swaps is no longer mandatory. | EMIR-VR-2048-01 |
| 2.5 | Unadjusted effective date of the price | New validation | Validation added: field should be populated with date of the day following the date reported in field 2.51 (Unadjusted end date of the price) for previous period | EMIR-VR-2050-02 |
| 2.57 | Effective date of the notional amount of leg 1 | New validation | Validation added: field should be populated with date of the day following the date reported in field 2.58 (End date of the notional amount of leg 1) for previous period in the schedule | EMIR-VR-2057-02 |
| 2.61 | Effective date of the notional quantity of leg 1 | New validation | Validation added: field should be populated with date of the day following the date reported in field 2.62 (End date of the notional quantity of leg 1) for previous period in the schedule | EMIR-VR-2061-02 |
| 2.66 | Effective date of the notional amount of leg 2 | New validation | Validation added: field should be populated with date of the day following the date reported in field 2.67 (End date of the notional amount of leg 2) for previous period in the schedule | EMIR-VR-2066-02 |
| 2.7 | Effective date of the notional quantity of leg 2 | New validation | Validation added: field should be populated with date of the day following the date reported in field 2.71 (End date of the notional quantity of leg 2) for previous period in the schedule | EMIR-VR-2070-02 |
| 2.77 | Other payment payer | Reconciliation condition | Reconciliation condition with field ‘Other payment receiver’ was removed | N/a |
| 2.78 | Other payment receiver | Reconciliation condition | Reconciliation condition with field ‘Other payment payer’ was removed | N/a |
| 2.82 | Fixed rate or coupon payment frequency period multiplier leg 1 | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 1 fixed rate or coupon (2.81) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2082-01 |
| 2.88 | Floating rate payment frequency period multiplier of leg 1 | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 1 floating rate period (2.87) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2088-01 |
| 2.9 | Floating rate reference period of leg 1 - multiplier | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 1 floating rate reference period (2.89) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2090-01 |
| 2.92 | Floating rate reset frequency period of leg 1 | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 1 floating rate reset frequency period (2.91) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2092-01 |
| 2.93 | Spread of leg 1 | Minor correction | Minor clarification removed – “otherwise this field shall be left blank” statement | EMIR-VR-2093-03 |
| 2.95 | Fixed rate of leg 2 | Minor correction | Minor clarification removed – “otherwise this field shall be left blank” statement | EMIR-VR-2095-01 |
| 2.98 | Fixed rate payment frequency period multiplier leg 2 | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 2 fixed rate (2.97) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2098-01 |
| 2.101 | Name of the floating rate of leg 2 | Minor corrections | Minor clarification added – Forward rate agreements added to the scope of validation Minor clarification – “otherwise this field shall be left blank” statement removed | EMIR-VR-2101-01 |
| 2.104 | Floating rate payment frequency period multiplier of leg 2 | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 2 floating rate period (2.103) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2104-01 |
| 2.106 | Floating rate reference period of leg 2 - multiplier | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 2 floating rate reference period (2.105) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2106-01 |
| 2.108 | Floating rate reset frequency multiplier of leg 2 | Minor correction | Minor clarification added – field should also be populated for interest rates instruments with leg 2 floating rate reset frequency period (2.107) payment at term (i.e. for all payment frequencies except ad hoc) | EMIR-VR-2108-01 |
| 2.109 | Spread of leg 2 | Minor correction | Minor clarification – “otherwise this field shall be left blank” statement removed | N/a |
| 2.111 | Package transaction spread | Minor correction | Clarified the wording by removing duplicated information | N/a |
| 2.116 | Base product | Minor correction | Typo correction – ‘ENVR’ replaced ‘ENRV’ | EMIR-VR-2116-01 |
| 2.117 | Sub-product | Minor correction | Typo correction – ‘FRTL’ replaced ‘FRLT’ | EMIR-VR-2117-05 |
| 2.12 | Interconnection point | Minor correction | Minor clarification – “otherwise this field shall be left blank” statement removed | EMIR-VR-2120-01 |
| 2.139 | Option premium amount | Minor correction | Minor clarification added – default value is accepted | N/a |
| 2.15 | CDS index detachment point | New validation | Validation added: field should be left blank for untranched derivatives | EMIR-VR-2150-02 |
| 2.153 | Event date | New validation Minor correction | Validation added: event date should be equal or later than execution timestamp (field 2.42) reports correction erroneous data fields of previously submitted report. Minor clarification – previously existing validation number shifted to EMIR-VR-2153-07 and EMIR-VR-2153-08 as the new validation is added as EMIR-VR-2153-06 | EMIR-VR-2153-06 EMIR-VR-2153-07 EMIR-VR-2153-08 |
| Field ID | Field Name | Change type | Conditions/Format & Content | Error Codes |
| 3.3 | Entity responsible for reporting | Minor corrections | Minor clarification added regarding leaving the field blank if validation conditions are not met. Corrected references to field IDs to correspond with Table 3 field IDs. | EMIR-VR-3003-01 EMIR-VR-3003-03 |
| 3.4 | Counterparty 1 (Reporting counterparty) | Minor correction | Corrected references to field IDs to correspond with Table 3 field IDs. | EMIR-VR-3004-03 |
| 3.6 | Counterparty 2 | Validation deleted Minor correction | Validation removed: requirement of first 20 characters of the Client Code to be equal to the LEI of Counterparty 1 Minor correction – adjusted numbering of further validations | EMIR-VR-3006-06 EMIR-VR-3006-07 |
| 3.8 | Collateral portfolio indicator | New validation | Validation added: Collateral portfolio indicator field value should match between corresponding reports in trades/positions report and margins report | EMIR-VR-3008-02 |
| 3.29 | Event date | New validation | Validation added: event date shall be equal or be later than the date of execution timestamp reported for the given derivative or derivative in the portfolio with earliest execution timestamp | EMIR-VR-3029-05 |
Non-Field-specific_Error_Codes A new tab was added with additional generic error codes. They are separated into three parts:
Technical validity of the XML file
Authorisation issues
Logical checks not covered by the VRs (a single generic code)
These changes are being incorporated in our solutions to help firms get ready for EMIR REFIT implementation in a streamlined and cost effective way. You can reach our team at bd@control-now.com if you require support in this process.