6. The Guidelines on position calculation published on 3 December 2018 (the 'existing Guidelines') have so far ensured harmonisation and consistency across position calculations and aggregations of derivatives by TRs. This has allowed authorities to obtain data aggregations of high standards and use the information to assess systemic risks to financial stability as well as act quickly in the case of a crisis.

7. In preparation for EMIR Refit go-live on 29 April 2024, ESMA launched a consultation paper in May 2023 with the aim to replace the existing Guidelines on position calculation to ensure full alignment with the requirements set out by EMIR Refit technical standards and the Guidelines on reporting under EMIR Refit.

8. A key topic covered in the consultation paper was determining whether TRs could implement a cost-efficient technical solution for generating the position report as of EMIR Refit go-live date and throughout the initial 6-month transition period while ensuring a high level of data quality. Several challenges with calculating positions using both updated and non-updated EMIR Refit data were recognised due to the different data standards that will coexist during the transition period.

9. Three alternatives were presented by ESMA: A) calculate positions using both pre- and post-Refit data as of EMIR Refit go-live, B) calculate positions as of EMIR Refit go-live using only data that have been updated to the latest standards or C) calculate positions only after the EMIR Refit transition period is over. According to the below table, each of these alternatives has certain advantages and disadvantages.