Backloading Collateral & Valuation Information under EMIR Rules

Since the updates to the EU & UK EMIR trade reporting regimes in April and September 2024, many reporting firms have been reviewing how to deal with the backloading of collateral and valuation information starting at the commencement dates of the updates to EMIR.

When entities undertake backloading for collateral and valuation data as necessary for EMIR, do you need to report the data for each day or only on the latest day? The short answer is that for incorrect historic data relating to margin, corrections are required for all days where data was incorrect or missing.

Requirement to report changes

Under the EMIR Rules (both EU & UK), entities are to ensure that the reports of their derivative trades contain details which are complete, accurate and reported on time (Article 9). The timeline for reporting a modification is the same as for the conclusion of a derivative, meaning when the modification is effective, it becomes reportable – "no later than the