71. In accordance with EMIR Article 9(1), counterparties and CCPs are required to ensure that the details of any derivative that is reportable as described in the section 3.2 are reported to a TR. Therefore, unless an exemption applies or unless a different party is responsible and legally liable for reporting pursuant to Article 9(1a) of EMIR, the reporting obligations apply to all counterparties and CCPs established in the Union as soon as they enter into a derivative contract. This means, that such a derivative should be reported no later than the working day following its conclusion, modification or termination.