45. In the Consultation Paper, ESMA summarized the legal background of voluntary delegation of reporting and reminded series of shortcomings addressed by EMIR REFIT and the newly designed allocation of responsibility for reporting. ESMA acknowledged the importance of field 9 'Report submitting entity' (RSE), reminded that currently it is often left blank, and proposed to make this field mandatory.

46. Respondents to the Consultation Paper did not raise any objections to this proposal and mostly supported it. Several respondents asked for more clarity regarding certain aspects.

47. Several respondents asked for clarification whether the reporting entities and entities responsible for reporting (ERRs) will be mandated to on-board the TR to be able to access the relevant data. One respondent highlighted client confidentiality issues with the data access. Access to data by all the relevant parties is covered in detail in section 6.

48. One respondent asked for further guidance on the maintenance of the RSE and how it should notify the TR that it will or no longer will submit data on behalf of the ERR. In case of voluntary delegation of reporting ESMA considers that the processes and timelines should be the same as for mandatory delegation covered in the previous section.