CSSF / ESMA – EMIR Reporting Updates: What Market Participants Need to Know

Future EMIR 3 Reporting Obligations

Following an ESMA communication, the CSSF draws attention to new reporting and notification requirements introduced by EMIR 3. In particular, these include obligations related to the Active Account Requirement (AAR) and notifications concerning clearing activity with third-country Central Counterparties (CCPs) recognised under EMIR. These requirements form part of the EU’s broader objective to strengthen financial stability and reduce excessive reliance on non-EU CCPs. Market participants should begin preparing for these additional legal reporting duties once the relevant regulatory technical standards enter into force.

EMIR Data Reconciliation

In a separate communication, the CSSF reminds market participants of upcoming enhancements to EMIR data reconciliation processes. From 29 April 2026, additional data fields will be used by Trade Repositories to reconcile reported derivatives transactions between counterparties. This development aims to further improve the accuracy, consistency and completeness of EMIR reporting data. Reporting entities are expected to review reconciliation feedback, correct discrepancies, and ensure robust internal controls to meet regulatory data quality standards.

Key Takeaway

Both communications relate to mandatory legal reporting obligations under EMIR, not voluntary best practices. They underline regulators’ continued focus on derivatives reporting quality, transparency and supervisory effectiveness, and signal the need for firms to adapt their reporting frameworks in line with EMIR 3 and enhanced reconciliation requirements.