On 6th of September 2023 ESMA have published their revised EMIR REFIT validation rules. Here is a detailed recap of the changes.

Changes to the Revised ESMA EMIR REFIT Validations

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.

Validations_Cpty_derivative

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
2.40	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
2.50	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
2.70	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
2.90	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
2.120	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
2.150	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

 

Validations_Margins

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 if you require support in this process.

 

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