EMIR
Derivatives reporting obligations in the EU: who reports, what is reported, and how submissions are validated and reconciled at trade repositories.
Last reviewed 1 Sep 2026
Overview
EMIR introduced a requirement to report derivative contracts to registered trade repositories. The reporting framework was substantially revised under the REFIT programme, which expanded and restructured the reportable data and moved submissions to ISO 20022 XML.
This page is a navigational summary. Always read the underlying regulation, technical standards and guidelines for authoritative requirements.
- ESMARegulation (EU) No 648/2012 (EMIR)27 Jul 2012Regulatory RequirementDemo
- ESMARTS on the details of reports to trade repositories (EMIR REFIT)7 Oct 2022Regulatory RequirementDemo
Reporting Obligation
Counterparties to derivative contracts are subject to the reporting obligation, with specific provisions on which entity is responsible for reporting in certain cases and on delegation of reporting to a third party.
Delegating submission does not by itself transfer every responsibility; firms typically maintain oversight controls over delegated reports.
- ESMARegulation (EU) No 648/2012 (EMIR)Article 927 Jul 2012Regulatory RequirementDemo
- ESMAGuidelines for reporting under EMIR14 Dec 2023Regulatory RequirementDemo
Data Fields
Reportable fields are organised into counterparty data, common data and specific sections such as margins and valuations. Field definitions, formats and allowable values are set out in the technical standards.
- ESMARTS on the details of reports to trade repositories (EMIR REFIT)7 Oct 2022Regulatory RequirementDemo
UTI
A Unique Transaction Identifier links both sides of a reported transaction. Guidance sets out which counterparty is responsible for generating the UTI and the expectation that it is shared in a timely way.
- BISCPMI-IOSCO Technical Guidance: Harmonisation of the Unique Transaction Identifier28 Feb 2017Industry GuidanceDemo
- ESMAGuidelines for reporting under EMIR14 Dec 2023Regulatory RequirementDemo
UPI
The Unique Product Identifier describes the product traded, using attributes defined by the UPI service provider's templates.
- BISCPMI-IOSCO Technical Guidance: Harmonisation of the Unique Product Identifier28 Sep 2017Industry GuidanceDemo
- ANNA DSBUPI Service — product definitions and templates15 Apr 2025Implementation ReferenceDemo
LEI
Counterparties and other entities in a report are identified using Legal Entity Identifiers. Validation typically checks both format and registration status.
- GLEIFLEI data and renewal status — GLEIF documentation1 Jun 2025Implementation ReferenceDemo
Trade Repository
Trade repositories receive submissions, apply validation rules, return feedback to reporting parties, and perform inter-TR reconciliation.
- DTCCDTCC GTR message specification (EMIR)3 Sep 2026Implementation ReferenceDemo
Lifecycle Events
Changes to a reported derivative are reported using a combination of action type and event type, for example a modification following a partial termination. Correct sequencing matters because validation can depend on the previously reported state.
- ESMAGuidelines for reporting under EMIR14 Dec 2023Regulatory RequirementDemo
- ESMAQuestions and Answers on EMIR data reporting21 Aug 2026Regulatory RequirementDemo
Validation Rules
ESMA publishes validation rules that trade repositories apply to submissions. Rules include format checks, conditional presence checks and consistency checks with previously reported data.
- ESMAEMIR REFIT validation rules and reconciliation tolerances11 Sep 2026Regulatory RequirementDemo
Reconciliation
Where both counterparties report, trade repositories attempt to pair and match the two sides, and reconciliation tolerances apply to specified fields.
- ESMAEMIR REFIT validation rules and reconciliation tolerances11 Sep 2026Regulatory RequirementDemo
Common Rejections
Practitioner-reported themes include missing or inconsistent UTIs on lifecycle events, action types that do not fit the trade's reported state, and invalid or lapsed LEIs. These are community observations, not an official list.
No citations — this section summarises community practice and is not a regulatory statement.
Implementation Questions
Open implementation questions from the community are linked from the discussions tagged EMIR. Reviewed answers are promoted into this section over time.
No citations — this section summarises community practice and is not a regulatory statement.
Regulatory Sources
Primary documents referenced on this page are listed below with their publisher and link to the official source.
- ESMARegulation (EU) No 648/2012 (EMIR)27 Jul 2012Regulatory RequirementDemo
- ESMARTS on the details of reports to trade repositories (EMIR REFIT)7 Oct 2022Regulatory RequirementDemo
- ESMAGuidelines for reporting under EMIR14 Dec 2023Regulatory RequirementDemo
- ESMAEMIR REFIT validation rules and reconciliation tolerances11 Sep 2026Regulatory RequirementDemo
- ESMAQuestions and Answers on EMIR data reporting21 Aug 2026Regulatory RequirementDemo