Are you confused with all the regulations and their different validation rules? – Be assured you are not the only one!


Last week on the 28th of January 2021 ESMA published an update on its EMR Q&A.

The updates are very modest and include only two clarifications:

  1. A clarification who needs to report “Seller” or “Buyer” if a position is netted, meaning leads to a quantity of zero (amendments to TR Question 3b)
  2. What actions need to be taken if a counterparty ceases to exist depending on whether it has a direct relation with the Trade Repository or not. (TR Question 57) 

TR Answer 57 is referring to an Action Code “ETRM” which is, however, not used under the current validation rules under EMIR.

So, for those who did not have the time yet to read through the entire “Draft technical Standards under EMIR REFIT” and who were not involved in the SFTR project, “ETRM” is referring to “Early termination”, which is currently and for at least the next 18 Months, reportable with action type “C” under EMIR. Under EMIR REFIT the Action Types will change from 1-letter codes to 4-letter codes most probably in the last quarter of next year. But these are by far not the only and the most far-reaching changes you need to expect.

As you see, not only market participants are sometimes confused about the different terminology and validation rules, but sometimes even the regulators lose their perspective. If you are looking for a reliable partner that can help you not losing track and actively supporting you in your regulatory reporting process, contact us under

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