REGnosys at EMIR Refit Forum: Key Takeaways and Insights 

Earlier this month, REGnosys had the privilege of sponsoring the Informa EMIR Refit Forum in the Park Plaza, Waterloo, London. 

The event brought together leading voices in regulatory reporting, providing an exchange of ideas and insights following the EMIR Refit changes having gone live earlier this year in both the EU and UK.   

Our Founder and CEO, Leo Labeis, outlines some of the key themes and learnings from this insightful day of keynotes, panels and networking. 

Best practice around errors and omissions

This first panel session of the day featured Chad Giussani (Compliance SME, Independent), Martin Kalnins (Regulatory Specialist, Swedbank) and Maria Caporale Madi (Head Global Transaction Reporting, Rabobank) on the best practice around errors and omissions. 

The discussion explored the dual-sided nature of EMIR reporting, highlighting its "social" aspect, requiring counterparties to work closely to manage errors and omissions. 

Unsurprisingly, the FCA’s preference for a risk-based approach to errors and emissions was widely endorsed by the panel over ESMA’s threshold-based method. 

During the discussion, the importance of striking the right balance between timelines and substance in reporting errors was discussed. Many firms are finding the back-reporting process particularly arduous, emphasising the need for efficient systems. 

Keynote from Jonathan Hamer, FCA

The keynote from Jonathan Hamer, Manager of the Post-Trade Reporting team at the FCA provided a snapshot of progress under the UK’s EMIR Refit. 

The first month of the new regime which went live at the end of September hint at an orderly transition, especially with regards to the global pace of change in 2024. Encouraging results include high ACK rates and over  50% of back-reporting uplift completed by October 31st. 

He also outlined that post-transition, the FCA will focus on reconciliations and pairing/matching, signalling the next phase of enforcement and that the UK’s rollout has been deemed a success. 

Navigating Regulatory Divergence

The panellists for this session included Andrew Head (EMIR Implementation Product Owner, Standard Chartered Bank), Kathryn Cenac (Director - Regulatory Services, Bank of Montreal), Mark Burnal (Head of Regulatory Operations & Fund Data, Man Group) and Miki Cheung (Regulatory Program Manager, Société Générale). 

The discussion explored the complexities of differing approaches between the UK and EU. The EU’s Refit was highlighted as more complex, reflected in day-one ACK rates of only 60%. 

While jurisdictions differ, firms should still look to standardise the backbone of their processes and controls. The majority of panellists reported modernising their architecture in preparation for the EMIR Refits.  

There was also recognition that divergence between regimes is here to stay despite harmonisation efforts. 

Lessons learned

The panellists for this session included Andy Leonard (UK/EMEA Regulatory Reporting Compliance Advisory Lead, Barclays), Avinash Shamdasani (Global Head of Trade & Transaction Reporting, BGC Partners), Michael Warren (Senior Transaction Reporting Analyst, Abrdn), Paul Rennison (Director, Strategy and Corporate Development, DeltaconX) and Prinz Sindac (Regulatory Reporting SME, MUFG Securities). 

During the session, there was recognition that the Refit went significantly more smoothly in the UK than the EU, helped by the 6-month gap. However, some of the more complex cans have been kicked down the road. 

Delegated reporting (DR) remains a critical, yet imperfect solution. There has been a significant increase in requests for DR mandates, but it’s not a silver bullet as “you can’t delegate the responsibility.”  

There are also cost challenges as charging clients for DR is still a virtual business impossibility, but costs are mounting for sell-side.  

Exploring the adoption, implementation and change management of required data standards

This panel was chaired by myself (Leo) and included Dawd Haque (Global Lead Market Initiatives, Regulatory Transformation & Strategy, Deutsche Bank), Emma Kalliomaki (Managing Director, Association of National Numbering Agencies (ANNA) & Derivatives Service Bureau (DSB)), Rav Saidha (Chair, Retail Derivative Forum) and Harry McAllister, (Director, Global Markets IT, BNP Paribas). Andy Leonard who was also scheduled to participate had to send regrets. 

The panel emphasised the importance of industry collaboration for the successful implementation of required data standards. While progress has been made, global harmonisation remains a work in progress, with further evolution of standards anticipated.  

Panellists also highlighted the need for greater clarity on the rules and processes guiding standardisation, even as standardising outputs prove beneficial. 

A big thanks to Avinash Shamdasani for chairing the conference and to Surath Devage and Informa for organising a seamless and engaging day. 

At REGnosys, we’re proud to support industry collaboration and innovation in regulatory reporting. As discussions around EMIR Refit continue to evolve, our commitment remains steadfast in delivering the compliance gold-standard and driving efficiency through our software platform Rosetta.