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Version date: 2 October 2019 - onwards
Version 2 of 2

TR Question 17: Position level reporting [last update 2 October 2019]

Article 9 of EMIR

Position level reporting

(a) Is it possible to report post-trade events at position level in addition to the trade level?

(b) A position may contain trades executed at different venues or both on and off exchange. How should the venue of execution (Table 2 Field 15) be populated at position level?

(c) Can a position be reported as being the result of compression, i.e. “Y” in field compression (Table 2 Field 16)?

TR Answer 17

(a) It is possible to use position level reporting as a supplement to trade level reporting provided that all of the following conditions are met.

1. The legal arrangement is such that the risk is at position level, the trade reports all relate to products that are fungible with each other and the individual trades have been replaced by the position. This could be the case, for example, between a clearing member and a CCP.

2. The original trades, i.e. at transaction level, have been correctly reported. It is not permissible to report only positions. Whenever an existing trade is to be included in a position level report in the same day, such contract is to be identified as "position component" by using the action type "P" in Table 2 Field 93. This value will be equivalent to reporting a new trade followed by an update to that report showing it as compressed. All contracts concluded on or after 12 February 2014 must be reported at the transaction level in all cases, starting 12 February 2014.