398. The notional is a key field and it is crucial that this field is populated correctly. Article 3(a) 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.

399. The CDE guidance provides detailed instructions regarding the reporting of notional for different OTC products. ESMA proposed 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.

400. The feedback received was generally supportive of the need for additional guidance on top of alignment with CDE guidance. Also, it was highlighted that while the CDE guidance provides a general framework for calculation, it does not cover non-standard commodity derivatives.

401. ESMA agrees that reporting of key fields such as notional should be further clarified and plans to provide additional guidance in the future guidelines on reporting.

402. Another aspect on which ESMA sought feedback in the Consultation Paper is reporting of notional at position level. Currently, EMIR Q&A TR 41 provides additional explanations on reporting of notional in position reports.