EMIR Refit Reporting: FX Swaps Should Be Reported As One Transaction
Key Takeaways
- FX swaps must be reported as a single transaction under EMIR Refit. EMIR Refit guidelines clearly require FX swaps to appear in one transaction report, removing the need to split into two or link trades with a package identifier.
- This differs from MiFIR’s two-report approach as under MiFIR, FX swaps are reported as two separate transactions (near and far legs), typically linked by a complex trade ID.
- Cross-regime differences create implementation challenges. Firms must apply regime-specific booking and reporting logic, as reusing MiFIR conventions under EMIR Refit leads to incorrect reporting.
Under EMIR Refit, FX swaps should be reported as a single transaction report rather than split into two legs. This differs from MiFIR conventions and requires firms to implement regime-specific booking and reporting logic.
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.
Reporting FX Swaps Within One Transaction Report
When traded on a venue, FX Swaps are traded as two Forwards therefore two separate transactions are concluded on the venue. In the subsequent MiFIR transaction report, FX Swaps are represented in two separate transaction reports (one for the near leg, the other for the far leg), linked by a complex trade ID.
In EMIR Refit, the guidelines clearly state that FX Swaps should appear in one transaction report therefore removing the need to separate into two and linking with a Package Identifier. The variation as to how FX Swaps are captured in a firms internal booking system have led to problems in the past with completing the transaction reports correctly. Therefore, aligning trade booking/capture systems with each reporting regime adds another layer of complexity to reporting.
Incorrect FX swap representation can cause validation rejects and trade repository pairing inconsistencies therefore important to model it correctly.
How Qomply can help
Learn how Qomply’s forensic technology and regulatory expertise delivers accurate, compliant EMIR Refit transaction reporting without the operational burden. Request a short demo to see how Qomply supports firms like yours and which tools may be most relevant to your regulatory obligations and reporting requirements.
Frequently asked questions
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They should be reported as one transaction report. The article says EMIR Refit removes the need to split the swap into two legs and link them with a package identifier.
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It differs because MiFIR represents venue-traded FX swaps in two separate transaction reports, one for the near leg and one for the far leg, linked by a complex trade ID. The article says EMIR Refit expects a single report instead.
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It says the difficulty comes from applying different booking and reporting logic across regimes. The article notes that internal trade-capture models often vary, which adds another layer of complexity when firms try to model FX swaps correctly.
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It can cause validation rejects and trade repository pairing inconsistencies. The article presents correct modelling of FX swaps as a control issue with immediate operational consequences.
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They should review whether their booking and reporting logic is aligned to EMIR Refit's one-transaction approach rather than MiFIR's two-leg convention. The article says regime-specific alignment is the practical control that matters most.