What changed in EMIR Refit for underlying asset reporting?

EMIR Refit split the legacy single underlying field into distinct reporting fields. Firms must now determine whether the underlying identification fields or the reference entity field should be populated.

What is the reference entity field used for under EMIR Refit?

The reference entity field is used when the underlying is not an index or basket and does not have an ISIN. It is typically populated with an LEI, for example for credit derivatives linked to loans.

When should underlying identification fields be used instead of the reference entity field?

Underlying identification fields should be used when the underlying instrument can be identified using the appropriate instrument identifiers (for example an ISIN, UPI, index or basket identifiers), rather than a reference entity.

Why is underlying asset reporting a common source of EMIR Refit breaks?

Firms may populate the wrong field due to ambiguity between underlying identification fields and reference entity requirements. Incorrect field completion can trigger TR validation rejects and reconciliation breaks.

How can firms reduce underlying asset reporting risk under EMIR Refit?

Firms should implement regime-specific validation checks, ensure identifiers such as ISINs and LEIs are accurate, and update internal workflows and training to reflect EMIR Refit field requirements.

EMIR Refit Underlying Asset Reporting: Reference Entity Field vs Underlying Identifiers

Author: Sophia Fulugunya

Director of Transaction Reporting
6 January 2025 | Updated 17 January 2026

EMIR Refit split the legacy “Underlying” field into distinct reporting fields. Firms must decide when to populate underlying identification fields versus the reference entity field (typically an LEI), especially for credit derivatives linked to loans. Mis-population is a common driver of TR rejects and reconciliation breaks.

Navigating the Reporting of Underlying Assets Under EMIR REFIT

The rollout of EMIR REFIT has introduced several new reporting fields aimed at improving clarity and accommodating the complexities of derivatives. A significant change is the addition of the reference entity field, which requires firms to carefully assess whether to populate the underlying identification fields or the reference entity field.

Under the original EMIR framework, a single "Underlying" field was used to report ISINs, LEIs, UPIs, indices, and baskets. EMIR REFIT has now split this field, prompting firms to update their systems and processes to ensure the correct application of each field.

Reporting When You Have an LEI

For cases where the underlying is not an index or basket and does not have an ISIN, EMIR REFIT mandates the use of the reference entity field to report the relevant details, typically an LEI. This requirement is especially pertinent for credit derivatives linked to loans.

The introduction of these additional fields means firms must be able to clearly differentiate between scenarios that require the underlying instrument fields and those that require the reference entity field to maintain compliance.

Key Considerations for Firms

1. Understand Field Requirements:

A thorough understanding of when to use the underlying identification fields versus the reference entity field is essential. Errors in this differentiation can lead to non-compliance and regulatory penalties.

2. Prioritise Data Validation:

Ensure ISINs and LEIs are accurate, valid, and current. Invalid identifiers can result in rejected submissions or heightened regulatory scrutiny.

3.Strengthen Internal Processes:

Update systems, implement robust internal controls, and provide thorough training to reporting teams to adapt seamlessly to the new requirements.

EMIR Refit underlying asset reporting and reference entity field

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Conclusion

The introduction of the reference entity field under EMIR REFIT adds complexity to derivatives reporting but also provides greater clarity for handling diverse underlying assets.

By adopting best practices and staying proactive, firms can navigate these regulatory changes effectively. At Qomply, we provide the expertise and solutions firms need to confidently manage their reporting obligations under EMIR REFIT.

Troubleshooting EMIR Refit

Reporting Underlying Assets: Reference Entity vs Underlying Identifiers