502. A key element for the correct functioning of the reporting regime under EMIR and ensuring the quality of derivative reporting is the validation by TRs of the data submission by the counterparties that are subject to the reporting obligation. Although Article 9(1)(e) EMIR as amended by EMIR REFIT, provides that "Counterparties and CCPs that are required to report the details of derivative contracts shall ensure that such details are reported correctly and without duplication.", with Article 78(9) and 78(10) EMIR as amended by EMIR REFIT also places responsibility regarding the procedures to verify the data on the TRs.

503. ESMA proposed in the Consultation Paper a framework for the collection of data and data validation performed by TRs consisting of:

a. Authentication of participants the TR should establish a secure data exchange protocol with the report submitting entities using (i) web identification for those using web upload, (ii) secure public/private key authentication for automated secure connections or (iii) other advanced authentication protocols.