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ARTICLE · 19 JUNE 2020

Changes To EMIR Reporting Responsibilities From 18 June 2020 – Key Considerations

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Derivatives reporting responsibilities under the European Market Infrastructure Regulation (EMIR) will change from 18 June 2020, as (i) alternative investment fund managers (AIFMs)...

United StatesFinance and Banking
Ezra Zahabi
Ezra Zahabi
Brian G. Albert
Brian G. Albert
Daniel Lynch
Daniel Lynch
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Derivatives reporting responsibilities under the European Market Infrastructure Regulation (EMIR) will change from 18 June 20201, as (i) alternative investment fund managers (AIFMs) will become responsible for reporting for their alternative investment funds (AIFs); and (ii) entities which are “financial counterparties” (FCs) will become responsible for reporting for their “NFC- entities”.

The changes do not apply to non-EU AIFs managed by non-EU AIFMs, which remain outside of the scope of the reporting obligations under EMIR. Non-EU AIFMs will need to be aware that they will be responsible for reporting for their EU AIFs, but may in practice delegate reporting to their contractual counterparties.

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