563. High data quality under EMIR is closely linked with reconciled data. Status "reconciled" is understood as the lack of difference between the values reported for each field by the two counterparties in their respective submissions to the TRs thus allowing the authorities to understand the economic terms of the derivative.

564. Based on the experience with EMIR, ESMA understands that certain fields, such as the free text ones could not be subject to reconciliation.

565. Moreover, few respondents proposed to establish logical dependencies between fields. However, ESMA confirms that logical dependencies are more relevant for validation than reconciliation. ESMA proposed in the Consultation Paper the establishment of a staged approach for inter-TR reconciliation where only a few "no tolerance" fields are included initially, and the list is subsequently extended. This staged approach would consist of two stages.

566. The first stage, which will comprise a reduced number of fields, will start together with the start of the reporting obligation under Article 9 EMIR as amended by EMIR REFIT.