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Version date: 1 November 2017 - onwards

TR Question 20a: Reporting to TRs: Empty fields

Article 9 of EMIR

Article 9 of EMIR - Reporting to TRs: Empty fields

Are all fields specified in the Annex of the Commission Delegated Regulation (EU) No 148/2013 mandatory? Can some fields be left blank?

TR Answer 20a

In general, all fields specified in the RTS are mandatory. Nevertheless, two different instances need to be acknowledged, namely:

1. The field is not relevant for a specific type of contract/trade, for example:

- commodity underlying field in case of equity derivatives,

- Domicile of the Counterparty in case of coverage by LEI.

2. The field is relevant for a given type of contract/trade, however:

a. there is a legitimate reason why the actual value of this field is not being provided at the time the report is being submitted, or

b. none of the possible values provided for in the Annex of the Commission Implementing Regulation (EU) No 1247/2012 for a given field apply to the specific trade.