processing the cash penalties outweighed the value of the penalties, though we were unable to get traction. We’ll now look to see if we can form an industry best practice guide on a de-minimis, as consultation with members suggest there’s appetite to do so.
EMIR Refit Reporting
The EU published EMIR reporting updates with a go-live date of the 29 April 2024. The update brings about an update to the amount of fields up from 129 to 203 and includes several new identifiers and reporting requirements, including the unique transaction identifier, unique product identifier, action and event type combinations and more.
The UK has published their own version of EMIR, with a go-live date of the 20 September 2024, with differences between the UK and EU versions of EMIR minimal. The FCA have also published draft validation rules and have indicated that they intend to set-up industry roundtables in the coming weeks to further discuss level 3 guidelines