Research European Commodity Market Regulations - Part 1 | Page 14

European Energy Market Regulations V3.1

Trade Reporting
EMIR and REMIT each have trade reporting requirements: EMIR for OTC and Exchange Traded
Derivatives, and REMIT for physical wholesale gas power, LNG and emissions trades as well as their
derivatives.
EMIR trade reporting is due in February 2014, with REMIT due in Q4 2014.
REMIT specifically has a goal of “avoidance of double reporting” which is intended to remove the
need to send any data twice under both EMIR and REMIT. This is turning out to be difficult in
practice.
In this section, we will first examine the trade reporting requirements of each rule set and then bring
them together.

Trade Reporting for EMIR
What must be reported?
EMIR requires all derivatives trades to be reported, by any party transacting them. This is in contrast
with Dodd Frank in two key ways:
1) Dodd Frank only requires OTC trades to be reported, EMIR requires Exchange Traded
deals(ETD) as well
2) Both sides of the trade must report, using the same Unique Trade Identifier (UTI).
It is likely that exchange traded deals could be reported by the exchanges themselves. However, the
obligation to report remains with the market participant. Since the request to delay such reporting
to January 2015 has been denied, exchanges do not have long to provide such solutions.
When deciding what a derivative is, careful consideration must be given to the type of instrument
and where it is executed. This is discussed in more detail in the “calculating the threshold “section.
Where data should be reported?
EMIR trade data must be reported to a registered “Trade Repository” (TR), a third party who will
make the data available to ESMA runs a trade repository. Four Trade Repositories were approved on
7th November, which are detailed in the second half of this report.
When reporting, market participants can either send data straight to TRs, get someone else to do it
on their behalf, or send the data via “Reporting Services”. All of these options are considered in the
services directory at the end of this report.
Which data must be reported?
Detailed data differs per asset class. However, the data can be divided into the following categories:
Entity Identification – Of the parties involved in the trade. Will include the reporting entity,
counterparty and others such as the beneficiary (if not the counterparty) broker etc.
Contract Information - Information about the deal and contract, including where it was
executed. UPIs preferred. Could require a complex product type derivation.
Transaction Information – Trade level details such as quantity, notional etc., requires the
Unique Trade Identifier.
Trade Type Specific Information - Different sets of fields for IR, FX, and Commodity etc.
Commodity profiles are multi record.
Option Information - Strike, call or put, etc.
Confirm Information – About the trade confirmation.

© Commodity Technology Advisory LLC and ETR Advisory Ltd, 2013, All Rights Reserved.

v3.1

November 13th, 2013

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