EMIR Refit | Navigating the Details

Client Codes Should Not Contain Personal Data

6 June 2023

As preparation has started for EMIR Refit, many regulatory reporting teams are cross-functional and may be involved in implementation of various regimes including MiFIR and EMIR. Whilst familiarity of multiple reporting regimes may be of benefit in aiding understanding of the requirements, there are some distinct differences between seemingly similar fields and the expectations of the required data. Therefore, it is important to be aware of the differences when navigating the details.

Client Codes Should Not Contain Personal Data

Client Codes, in EMIR Refit, are internal identifiers used to identify individuals in transaction reporting.

The construction of those identifiers in EMIR Refit transaction reporting is different from the conventions adopted in MiFIR reporting. In MiFIR, the Client Code is a composition of various pieces of personal data, in EMIR Refit, however, the ESMA guidelines clearly state that the identifiers should be unique at the level of the reporting counterparty (Counterparty 1) and should not contain any personal data. Therefore, the same identifier created for MiFIR should not be used in EMIR Refit reporting. (220)

Regulatory reporting teams responsible for delivering both EMIR and MiFIR should ensure that the client codes are different between the two regimes and personal sensitive data are not included in EMIR Refit reports.

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