141. As specified in the UPI guidance, each UPI code would map to a set of data comprised of reference data elements with specific values that together describe the product. The reference data elements with the respective values would reside in a UPI reference data library. The UPI library would be maintained by the UPI provider and would be accessible to the data users.

142. In the Consultation Paper, ESMA explained that in the future ESMA could consider eliminating requirement to report some or all UPI reference data in the trade reports submitted to the TRs, on the condition that the derivative is identified with the UPI and the UPI framework is fully implemented allowing the authorities, reporting entities and TRs to easily access the UPI reference data. ESMA also asked about the costs attached to the continuation of reporting of those reference data that are already required to be reported under the current technical standards, with a view to assess the burden to the industry should the key fields be required to be reported in the future irrespective of the availability of the UPI reference data library.

143. Majority of respondents expressed preference for removing all reference data from EMIR reporting obligations once UPI becomes available, stating that this would reduce redundancies, eliminate necessity to update derivative reports when only reference data of the product change, improve data quality and increase reconciliation rates. Furthermore, respondents questioned the argument in the Consultation Paper that reporting of key fields would facilitate validation of the reports and determining data access rights by the TRs.