FinfraG / FMIA
Art. 104 Reporting (TR)

The deltaconX regulatory platform enables FinfraG / FIMA Article 104 Derivative Reporting compliance so that your day-to-day operations are streamlined and your ability to work is optimised.

The Swiss Financial Market Infrastructure Act (FMIA), also known as the German denomination FinfraG (Finanzmarktinfrastrukturgesetz), is a framework designed to harmonize Swiss regulations with international standards that came into force January 1st 2016.

Article 104 is the Swiss version of EMIR and covers the reporting of Derivative contracts to a TR, which helps align requirements for eligible parties.

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What is the reporting obligation?

The Swiss Financial Market Infrastructure Act, or FinfraG for short, has imposed a number of obligations on the counterparties to a derivative transaction, including the obligation to report transactions belonging to the following asset-class categories:

Who is required to report?

FinfraG Art 104 imposes a prescriptive ‘Cascade’ principle on who must report, which makes it a ‘Single Sided’ regime (unlike EMIR), and requires the following to report:

It is important to note that trading between small Non-Financial Counterparties is exempted from reporting, and that participants are considered to be small if they do not exceed the clearing threshold.

When do reports have to be made?

Reports must be submitted to a recognised TR the next Business Day (T+1).

What does EMIR Refit mean for Swiss counterparties?

Switzerland does not recognize EMIR, making EMIR Refit is not legally enforceable on trades within Switzerland.

However, when Swiss counterparties transact with EU counterparties there are indirect implications for EMIR Refit in the same way as with EMIR, with the onus being on the Swiss counterparty to determine which EMIR category it falls under.

So in order to eliminate the obligation to clear, Swiss FCs need to make sure to verify whether they fall under the new FC- categorization under EMIR or not. What is also important to note is that as the EMIR thresholds differ from the Swiss thresholds, any such verification will have to be performed separately from any determination under the FMIA, i.e., an FC- under the FMIA is not necessarily an FC- under EMIR.

In order for a firm established in Switzerland to successfully determine if they would have been classified as an FC they can simply look at what their classification would have been if they had been established in the EU. If it had been established in the EU and thereby fulfils the FC requirement, then the Swiss firm will qualify as an FC from the EMIR perspective.

User-friendly compliance

A platform that helps you focus on what matters.

deltaconX provides highest flexibility by supporting multiple jurisdictions within a unified platform.

Fully Integrated FinfraG Swiss Exchange Reporting

The deltaconX SaaS platform offers the capability to incorporate the FinfraG Article 104 Derivative Reporting requirements into our unified and standardised workflow, so that you only need to focus on the areas in need of attention.

We completely remove any confusion surrounding the requirements for FinfraG Article 104 Derivative Reporting compliance by ensuring that the required data is captured and provided to satisfy FinfraG / FMIA compliance requirements.

Because our unified deltaconX workflow is built to focus your attention only where it’s needed, meeting the FinfraG Article 104 Derivative Reporting have never been easier as all the requirements are built into our platform itself.

Integrated Compliance Expertise

We help you move away from relying on external consultants or trying to maintain complex internal solutions that eat up significant amounts of time and resources, by reducing the burden of compliance.


Our platform has the combined experience from across the entire data reporting chain integrated so that you can finally eliminate the need for expensive in-house and switch to a simpler way of working with a platform that reduces manual efforts by up to 80%.

In this sense, deltaconX makes it both quick and easy to make sure that everything is available to validate your FinfraG Article 104 Derivative Reporting without driving up the pressure on your existing resources.

By building expertise from across our entire data reporting chain into the platform itself, we’re also able to proactively work on bigger shifts, changes, or even revisions to the regulations without passing the burden on to you.

Evergreen Compliance is Futureproofed Compliance

As the regulatory reporting bodies start to move their focus away from data completeness towards data quality, remaining compliant will prove to become a bigger challenge over time.

Unlike other solutions deltaconX can actually provide you with the complete picture of the cost of FinfraG Article 104 Derivative Reporting compliance with an unprecedentedly clear TCO even as reporting compliance requirements change over time.

With deltaconX you get more than just a SaaS based solution provider, you get a long-term partner that will proactively help you reduce the burden of compliance by freeing up resources that can start focusing on your core business.