Published: 25th January 2017

Of relevance to:  those entities subject to EMIR


It’s now nearly three years (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:

  • entered into before 16 August 2012 and were still outstanding at that date; and
  • entered into on or after 16 August 2012

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

We would remind firms that the final reporting time frame ends 12 February 2017 as per Article 5(4) of Implementing Regulation 1247/2012- see Regulatory Roundup 62.

Therefore, those derivative contracts which were not outstanding on 12 February 2014 but which:

  • were entered into before 16 August 2012 and were still outstanding on 16 August 2012; or
  • were entered into on or after 16 August 2012

must be reported by 12 February 2017.

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