170. Counterparties and CCPs are required, pursuant to the Article 9(1) of EMIR as amended by EMIR REFIT, not only to report conclusion of a derivative but also "any modification or termination of the contract". Sufficiently detailed and transparent requirements on reporting of lifecycle events are necessary to ensure that the authorities can obtain a holistic and accurate view of the exposures in the market at any point in time. Therefore, this information is pivotal for the monitoring of the systemic risk and for increasing the transparency of the derivatives market.

171. The current RTS and ITS on reporting include a dedicated reporting field 'Action type' in which a counterparty must declare what is the content of the given report, in particular, whether it is triggered by a new trade, by a lifecycle event or if it is related to correcting an previously reported inaccurate data. The information reported currently is however insufficient to provide the authorities with a good understanding of the business event triggering the report as well as does not allow to establish logical links between different derivatives which are created, modified or terminated due to the same business event.