249. The CDE guidance defines the 'Effective date' as the date at which obligations under the OTC derivative transaction come into effect, as included in the confirmation, whereas the current RTS simply refers to the "Date when obligations under the contract come into effect".

250. ESMA proposed to align the definition of 'Effective date' to CDE guidance by referring to the confirmation date. The reporting of 'Effective date' is further clarified in EMIR TR Q&A 48, where it is explained that, where the counterparties did not specify the effective date as part of the terms of the contract, field 'Effective date' shall be populated with the date of execution of the derivative. ESMA considered that the proposed definition of Effective date, aligned with the CDE guidance, as complemented by the EMIR Q&A, does not need further explanations, and proposed to retain it.