1. ESMA performed a field relationship analysis between the current and new reporting standards to assess and identify possible backward-compatibility issues that could prevent TRs from calculating positions efficiently and accurately during the transition period when pre- and post-EMIR Refit data would coexist.

Q1: Based on the field relationship analysis, please list any critical issues that might prevent TRs from calculating positions using pre- and post-EMIR Refit data during the transition period?

2. One respondent suggested to implement the Position Aggregation reporting changes after the transition period, because the data will be updated to the new standards by then.

3. Two respondents asked how should records where pre-REFIT T2F7 'Underlying Identification Type' is populated with code 'A' (AII - Alternative Investment ID) be aggregated, given that post-REFIT T2F13 'Underlying Identification Type' does not allow to be populated with code 'A'. According to the understanding of one of the respondents, this would imply the creation of another aggregation, valid only during the transition period.