6.1.3 Uniqueness of derivatives and special fields (paras. 566-570)
566. The uniqueness of a derivative until the application of the revised RTS on reporting was ensured at the level of the combination of LEI1-LEI2-UTI. It should be noted that TRs used this unique combination to incorporate any modification or the termination to the derivative.
567. From the date of application of the revised technical standards on reporting under EMIR the uniqueness of derivatives concluded after that date should be ensured at the level of the UTI, i.e. for the derivatives concluded after that date there should not be two same UTIs, no matter the combination of counterparties. This is of course notwithstanding that for double-sided reports (i.e. where both sides report under EMIR), the same UTI would appear twice, reported by either of the counterparties.
568. From that date onwards, TRs should therefore use the full triplet (LEI1-LEI2-UTI) only to update the state of the derivatives concluded prior to the application date of the RTS on reporting. To update the state of derivatives concluded after the application date of the RTS on reporting, the TRs can use the combination LEI1-UTI. For simplicity, the TRs can use full triplet in all cases to update the state of the derivative (incl. derivatives concluded after the application date of the RTS on reporting) . The uniqueness of the newly reported UTIs should be ensured by the counterparties and ERRs when reporting and by the TRs when verifying the reports in accordance with the validation rules.