Published: 25th February 2015

It’s now a year (12 February 2014) since the reporting obligation to report to a Trade Repository under EMIR came into force.

Firms subject to the EMIR reporting obligation may recall that there were phased reporting windows depending whether the contracts were:

i) entered into before 16 August 2012 and were still outstanding at that date; and

ii) entered into on or after 16 August 2012

The 16 August 2012 is the date that EMIR, but not its provisions, came into force.

Those transactions that were still outstanding on 12 February 2014 that fell within (i) had to be reported within 90 days of that date whilst those within (ii) had to be reported on 12 February 2014.

We would remind firms that they now have a two year time frame (being three years from 12 February 2014) to report any contracts that fall within (i) or (ii) but which were not outstanding on 12 February 2014 – see Article 5(4) of Implementing Regulation 1247/2012.

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