When it comes to EMIR, the absence of a trade report isn’t just an oversight — it’s a regulatory failure. Unlike rejections or mismatches, missing trades don’t generate alerts. Without an inbound trade feed to the trade repository, there’s nothing to reject or match against — meaning the absence passes silently.
Underreporting can result from:
Broken trade capture processes
Errors in report filtering logic, excluding valid trades
Missing lifecycle events for previously reported trades (e.g., modifications or terminations not sent)
Transmission failures between internal systems and the trade repository
Lapses in delegated reporting oversight
Because these trades never reach the trade repository, there’s no immediate flag to trigger investigation.
Key risks include:
Non-compliance with EMIR obligations
Inaccurate exposure and risk reporting at the systemic level
Regulatory enforcement or public censure during audits or investigations
Even when reporting is delegated, the legal obligation for completeness remains with the counterparty — making independent oversight essential.
To mitigate this risk, firms should:
Reconcile internal trade records against reports submitted to the trade repository
Use acknowledgements and receipt files from trade repositories as verification
Perform periodic completeness reviews (daily for high-volume products, monthly for lower-volume portfolios, depending on risk appetite)
Apply rigorous oversight to delegated reporting arrangements
The real danger of underreporting is its silence. Without controls designed to highlight absence, these gaps may go undetected for months — or longer. That’s why strong reporting oversight needs to prioritise completeness as highly as it does accuracy.