411. In the Consultation Paper, ESMA proposed to consider two alternative approaches for reporting of notional amount schedules. Under the first option, in line with the CDE guidance, the counterparties would report the notional amount schedules upfront (when reporting with action type 'New') using a repeatable section of fields (unadjusted date on which the associated notional amount becomes effective, unadjusted end date of the notional amount, notional amount which becomes effective on the associated unadjusted effective date). Alternatively, the counterparties would not be required to report notional schedules but would need to update the notional (by sending a report with action type 'Modification') each time when it changes according to the schedule.

412. The vast majority of the respondents supported the first option of reporting the notional amount schedules upfront.

413. Based on this feedback, ESMA will proceed with the first option of reporting the notional amount schedules upfront.

414. At the same time, ESMA clarifies that any updates to the notional amount that are not linked to an agreed upfront notional schedule, must be reported as a modification.