What Does EMIR Require?
EMIR’s T+1 rule is straightforward in theory: firms must report derivative transactions by the end of the next working day. But in practice, achieving consistent timeliness across multiple asset classes, counterparties, and data sources is a significant operational challenge. Cross-system dependencies, last-minute trade amendments, or late allocations can all put pressure on reporting workflows.
Why Reports Go Late
Delays can be caused by system outages, failures in file delivery, upstream data gaps, or manual bottlenecks. While one-off issues might be understandable, repeated lateness suggests deeper control weaknesses. While one-off issues might be understandable, repeated lateness indicates deeper issues in oversight, capacity planning, or ownership of the end-to-end reporting chain.
Why It Matters
- T+1 is a legal obligation, not a best-efforts target
- Late files can trigger regulatory review, especially if they form a pattern
- Reporting failures reflect poorly on broader risk and compliance culture
In recent regulatory reviews, firms have been challenged not just on whether reports were submitted, but whether they could demonstrate consistent monitoring, effective escalation, and evidence of remediation when issues occurred.
What Good Control Looks Like
Timeliness must be actively monitored. Daily controls, such as internal testing with dummy trades, should track whether all scheduled submissions occurred as planned. Where files are late or fail, alerts should trigger investigation. Logs must capture explanations and document corrective actions.
Final Thought
A robust reporting framework doesn’t assume compliance — it verifies it. And in the case of EMIR, lateness isn’t an operational nuisance. It’s a regulatory exposure.
Looking to strengthen your EMIR controls? Speak with our EMIR team today.
