TR Answer 18

Article 4 of the Commission Implementing Regulation (EU) No 1247/2012 specifies that in absence of global unique trade identifier endorsed by ESMA, a unique code should be generated and agreed with the other counterparty (Table 2, field 12). This means that only one Trade ID should be applicable to any one derivative contract that is reported to a trade repository under EMIR and that the same Trade ID is not used for any other derivative contract. It is also acknowledged that contracts reported under EMIR rules might also reported under the rules of other jurisdictions. Hence, the same Trade ID should be allowed to be used in both those jurisdictions for reporting the given contract in order to facilitate the reconciliation among all the data sets.

Commission Implementing Regulation (EU) No 148/2013 (RTS on reporting to TR) specifies that the Trade ID can have up to 52 characters, including four special characters, the special characters not being allowed at the beginning or at the end of the code. Therefore, a Trade ID that is less than 52 characters in length is permissible provided that it meets the other criteria laid out here. There is no requirement to pad out Trade ID values to make them 52 characters long.