Best Practices

EMIR: Reporting Entity Fields

The ERR identifies the entity that will be responsible for notifying its competent authority and if different, the competent authority of the reporting counterparty of any of the following instances, as indicated in Article 9 of the ITS:

  • any misreporting caused by flaws in the reporting systems that would affect a significant number of reports;
  • any reporting obstacle preventing the report submitting entity from sending reports to a trade repository within the deadline referred to in Article 9(1) of Regulation (EU) No 648/2012;
  • any significant issue resulting in reporting errors that would not cause rejection by a trade repository in accordance with Commission Delegated Regulation (EU) 2022/1858

Original Table extracted from the Final Report on the Guidelines for reporting under EMIR

Table – Population of the fields pertaining to counterparties, report submitting entity and entity responsible for reporting
Scenario Report submitting entity (field 1.2) Entity responsible for reporting (field 1.3) Counterparty 1 (field 1.4) Counterparty 2 (field 1.9)
FC reporting on behalf of NFC- in accordance with Article 9(1a) Leg 1 FC LEI FC LEI FC LEI NFC- LEI
Leg 2 FC LEI FC LEI NFC- LEI FC LEI
FC reporting on behalf of NFC- in accordance with Article 9(1a) and FC delegating to RSE Leg 1 RSE LEI FC LEI FC LEI NFC- LEI
Leg 2 RSE LEI FC LEI NFC- LEI FC LEI
NFC- opting out from FC reporting on their behalf in accordance with Article 9(1a) Leg 1 FC LEI FC LEI FC LEI NFC- LEI
Leg 2 NFC- LEI NFC- LEI NFC- LEI FC LEI
NFC- opting out from FC reporting on their behalf in accordance with Article 9(1a) FC delegating to RSE NFC- delegating to RSE2 Leg 1 RSE LEI FC LEI FC LEI NFC- LEI
Leg 2 RSE2 LEI NFC- LEI NFC- LEI FC LEI
NFC+ delegating to FC Leg 1 FC LEI FC LEI FC LEI NFC+ LEI
Leg 2 FC LEI NFC+ LEI NFC+ LEI FC LEI
NFC+ delegating to FC and FC subdelegating to RSE Leg 1 RSE LEI FC LEI FC LEI NFC+ LEI
Leg 2 RSE LEI NFC+ LEI NFC+ LEI FC LEI
NFC+ not delegating to FC Leg 1 FC LEI FC LEI FC LEI NFC+ LEI
Leg 2 NFC+ LEI NFC+ LEI NFC+ LEI FC LEI
Counterparty trading with a natural person not eligible for an LEI delegating to RSE Leg 1 RSE LEI CP 1 LEI CP 1 LEI Client code as specified in ITS on reporting for field 1.9
No Leg 2 reporting required
The contract is an ETD Leg 1 FC LEI FC LEI FC LEI NFC- LEI
Leg 2 NFC- LEI NFC- LEI NFC- LEI FC LEI