362. According to the Article 9(1e) of EMIR, counterparties and CCPs should report correctly and without duplication. Quality of data reported by counterparties is a key aspect to ensure wide usability and quality of data analytical results. Further requirements for ensuring the data quality on the counterparty side are se out in Article 9 of the draft ITS on reporting and Article 1 and 3 of the draft RTS on data quality.

363. Apart from implementing a common set of validation rules providing an immediate response on the quality of data at the point of data submission, TRs should implement a reconciliation process consisting in paring and matching of the reports pertaining to both sides of the derivative to compare the content of the reports and flag the inconsistencies indicating misreporting by at least one of the counterparties. TRs should provide detailed information on rejections and reconciliation to the relevant participants and users of the TR and also to NCAs. Reporting counterparties, report submitting entities and entities responsible for reporting, as applicable, should investigate the data quality issues flagged by data rejections and unsuccessful reconciliation, and ensure data correction. The draft ITS also specifically requires the entities responsible for reporting and the report submitting entities, as applicable, to have in place arrangements which ensure that the feedback on the reconciliation failures provided by the TRs is taken into account.