EACT Response to ESMA's Consultation on the technical standards on reporting under Article 9 of EMIR

The EACT has submitted a response to the European Securities and Markets Authority's (ESMA) consultation on the technical standards on reporting under Article 9 of EMIR. We are supportive of ESMA's efforts to provide enhancements that will clarify and simplify reporting requirements but we highlight that sufficient lead-time for implementation by non-financial counterparts must be foreseen. We also propose that the scope of the reporting requirement should be focused on areas of increased inherent risk and transactions that are not systemically risky e.g. intragroup transactions of non-financial counterparties and FX contracts used for commercial/hedging purposes should be excluded from the scope.