279. The notional is a key field and it is crucial that this field is populated correctly. Article 3a of the current RTS on reporting state how the notional should be populated for certain derivative contract types. The current RTS on reporting also provide definitions of “notional amount” and “quantity”, while the current ITS on reporting prescribe in what format the relevant fields shall be populated.

280. EMIR Q&A TR 41 provides additional explanations on reporting of notional in position reports.

281. The CDE guidance provides detailed instructions regarding the reporting of notional for different OTC products. ESMA proposes that the content of that guidance is used for reporting of notional under EMIR for OTC derivatives and be included into the draft RTS on reporting.

282. There is however limited guidance/clarity on how the quantity field should be populated, which causes data quality issues with the population of this field. In some instances, counterparties populated the same value in the quantity and notional field. In other instances, counterparties seem to assume that the total quantity of the underlying should be reported in this field.

283. Furthermore, the applicability of this field, as well as of the field “price multiplier” is limited to the products traded in lots. For the remaining products, the requirement to report these fields creates confusion and results in inconsistent practices. Consequently, it is proposed to remove the fields “Price multiplier” and “Quantity”. Instead, it is proposed to add the field “Total notional quantity” as envisaged in the CDE guidance.