Navigating EMIR Refit go-live & mandatory LEI reporting obligation updates

Published on 25 March, 2024
By LEI Worldwide


EMIR (European Market Infrastructure Regulation) was first introduced in July 2012, now from the 24th April 2024 EMIR Refit (regulatory fitness and performance programme) revised rules will apply.

The EMIR Refit is one element of the European Comission’s “Better Regulation” agenda.

EMIR was originally an EU regulation introduced to increase transparency and reduce risk through standardisation in financial markets. Similarly, following Brexit UK EMIR (September 2024) is the UK's on-shored version of EMIR and more information can be found at the FCA.

What is changing?

In summary, there are updates to reporting obligations, tighter and more enhanced standardisation controls. THe main areas this will apply are OTC derivative products, mitigation techniques, and reporting obligations. With regards to the LEI, financial institutions will be required to liaise with their counterparties in order to ensure all LEIs are currently up to date. 

The overall major updates will include:

  • The number of reporting fields will increase from 129 to 203. 
  • Format of Data Transmission will update to the ISO 20022-XML format 

Under EMIR, mandatory regulatory reports on derivative contracts (including futures, options, swaps, forward rate agreements and other financial instruments) traded by EU counterparties must be submitted via a Trade Repository approved by the relevant authority (ESMA or the FCA, UK).

These reports will undergo quality checks and analysis by regulators to ensure compliance and in order to identify systemic risk. The use of the LEI plays its role in increasing transparency and reducing risk by making entity and counterparty data more accessible, standardised and open. 

ISO 17442

The LEI is a global ISO standards (17442) and each reporting counterparty shall be identified by way of a 20 digit Legal Entity Identifier (LEI). The EMIR Refit will apply stricter rules to data quality, with an added duty to keep LEIs ‘up to date’. This emphasises the importance of maintaining an active LEI. Previously many organisations have been trading on Lapsed LEIs. 

Article 208 of the ESMA Guidelines for reporting under EMIR published in October 2023, states:

“According to the Article 3 of the ITS on reporting, the ISO 17442 Legal Entity Identifier (LEI) code should be used to identify a broking entity, a CCP, a clearing member, a counterparty which is a legal entity, a report submitting entity, an entity responsible for reporting, and a post-trade risk reduction service provider.” 

Article 211 emphasises for accuracy the LEI be kept up to date (renewed):

 “In order to reduce reporting issues due to lapsed LEI, the LEI code of the counterparty 1 and the entity responsible for reporting should be, for the purpose of reporting any new derivative or any modification, duly renewed and maintained according to the terms of any of the endorsed LOUs (Local Operating Units) of the Global Legal Entity Identifier System.”



Should you be operating within a financial institution which falls under the EMIR refit, please ensure your LEIs are all maintained, active and managed on a single dashboard which has multiple user friendly features such as system alerts, lapsing notifications, watchlist tools and a consolidation feature.

For example, a useful watchlist tool will allow you to keep an eye and monitor your counterparties LEIs to ensure they also, are up to date which will ease the monitoring element of counterparty LEIs.

If you would like to discuss your EMIR Refit readiness with regards to your LEIs, and your counterparties LEIs please contact us here. 

FAQ on emir refit & LEI:

  1. Q1. What is EMIR Refit?

    • EMIR Refit refers to the regulatory fitness and performance program aimed at enhancing and updating the European Market Infrastructure Regulation (EMIR) to address emerging market dynamics and regulatory needs.
  2. Q2. What are the key changes introduced by EMIR Refit?

    • EMIR Refit introduces various updates, including revisions to reporting obligations, tighter standardization controls, and enhanced requirements for LEI (Legal Entity Identifier) management.
  3. Q3. How does EMIR Refit impact LEI requirements?

    • Under EMIR Refit, financial institutions must ensure that LEIs are actively maintained and kept up to date. This involves renewing LEIs as necessary and monitoring counterparties' LEI status to ensure compliance.
  4. Q4. Why is LEI management crucial under EMIR Refit?

    • LEIs play a vital role in increasing transparency and reducing risk in financial markets. Active LEI management ensures accurate reporting and helps identify systemic risk, contributing to regulatory compliance and market integrity.
  5. Q5. How can organizations prepare for EMIR Refit regarding LEI requirements?

    • Organizations should prioritize maintaining active LEIs and implementing robust LEI management processes. This includes using a centralized dashboard for LEI management, setting up system alerts for LEI renewals, and monitoring counterparties' LEI status.
  6. What are the implications of non-compliance with EMIR Refit?

    • Non-compliance with EMIR Refit, including failure to maintain active LEIs, can result in regulatory penalties, operational disruptions, and reputational damage. It is essential for organizations to adhere to EMIR Refit requirements to avoid such consequences.
  7. How can LEI Worldwide assist with EMIR Refit compliance?

    • LEI Worldwide offers comprehensive LEI management solutions tailored to EMIR Refit requirements. Our platform provides features such as LEI renewal alerts, counterparties monitoring, and consolidation tools to streamline compliance efforts.
  8. Where can I learn more about EMIR Refit and LEI compliance?

    • For further information on EMIR Refit and LEI compliance, you can refer to regulatory guidelines, industry publications, and consult with LEI service providers like LEI Worldwide.

This FAQ provides insights into EMIR Refit's impact on LEI requirements and offers guidance on compliance measures, helping organizations navigate regulatory changes effectively.

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