Is reporting at ‘position level' allowed for all EMIR Derivatives?

Differences between trade level reporting vs position level reporting are important to note as part of transaction reporting – TRAction previously discussed them in this article. Position level reporting basically targets aggregated data to show overall exposure across the counterparties concerned.

Under EMIR, reporting at position level for all derivatives is not permissible and can only be done for 3 types of derivatives:

• Contracts for Difference (CFDs),
• Exchange traded derivatives (ETDs) and
• centrally-cleared OTC derivatives.

Although both the EU and UK regimes are in agreement on position level reporting, there are slight nuances between the approaches taken by the FCA and ESMA and which we discuss below.