3.1.1 Transition to reporting under the RTS and ITS on reporting

Q1: Are there any other clarifications that should be provided with regards to the transition to reporting under the revised technical standards?

1. In the Consultation Paper on the Guidelines (CP), ESMA clarified the aspects concerning the transition to reporting according to the revised RTS and ITS on reporting.

2. The approach proposed in the CP has been broadly supported, however several respondents asked for additional explanations.

3. In the CP ESMA explained how the counterparties should update all their outstanding derivatives both at a trade and at a position level in the course of the transition period, and the relevant action types that should be used. ESMA also clarified that the transition period does not impact in any way the obligation under Article 9 of EMIR to report the relevant events by T+1 and that all the reports submitted after the start of reporting under the revised technical standards will have to comply with the amended requirements.