4.1 Annex I - Cost-benefit analysis

128. As indicated in sections 1 and 4 of this final report, these guidelines establish a consistent and harmonised approach and a comprehensive procedure to carry out position calculations as required in accordance with EMIR Article 80(4). The guidelines cover the procedures TRs should follow to calculate the four different datasets which ESMA has proposed are necessary for authorities to monitor financial stability.

129. ESMA is including a reduced cost-benefit analysis outlining the qualitative assessment of the impact of the guidelines to TRs. Included in this analysis are costs which were fed back from consultation paper respondents. These guidelines provide clear instructions to TRs who are legally required to produce position calculations. They leverage off the trade state information, which the TRs are already required to produce. This reduces any potential additional costs of calculating positions.

130. The guidelines also build on already existing requirements for TRs such as ISO 20022 XML file format, SFTP channel for data transmission, data cut-off time used to produce trade state data and ECB currency conversion rates.

131. On the data availability and record-keeping side, the incremental costs for TRs are also minimal, as ESMA’s simulation exercises indicated that the additional burden in terms of the volume of records that a TR will produce will increase by 4%, not a significant amount.