ESMA Annual Report Provides Anticipated Year One EMIR REFIT Stats
A year into the go-live of the EMIR REFIT, many firms were awaiting the 2025 ESMA Data Quality report to provide regulatory feedback on the new reporting standards of the regulation. The REFIT aimed to improve data quality of information available to ESMA and EEA regulators.
Released on nearly the anniversary of the 2024 go-live, the ESMA Data Quality Report was published last week. The annual study produced by ESMA covers their review of EMIR, SFTR and MIFIR submissions. Now in its fifth edition, ESMA’s analysis provides details on data quality rates and troublesome fields that are useful when benchmarking one’s results to the wider industry along with offering areas firms can focus their internal reviews on.
For EMIR, the report feedback is split between REFIT specific trends and general Data Quality Indicators (DQI). The DQI were created to provide standardized monitoring for ESMA and NCAs on key data quality data points that are important parts of their supervision of the regulation. They include reviews of specific fields that are known to be problematic and lifecycle event management.
Key EMIR takeaways of the report include:
Trade Repository rejection rates: With the move to the ISO 20022 XML format for all submissions, teething issues were expected for submissions of files. According to ESMA, at go-live, file level rejection rates were 0.23% but have since declined to 0.0047% as of February 2025.
For field level rejections that cover percentage of records with an error, they were initially at 20% at go live and have since fallen to a range of 1-2.5%. This compares to 1.4% pre-REFIT. In the report, ESMA highlighted that overall the current rejection rates are higher than pre-refit figures and its an area they want to see improvement with.
Updating open positions: One of the requirements under EMIR REFIT was that positions opened prior to the go-live with a maturity rate longer than 180 days had 180 days to update trade details with the new REFIT data standards. According to ESMA there were 12 million derivative positions that fell under this category. As of February 2025, only 2% of trades of these pre-REFIT positions have yet to be updated with new required information.
Pairing & Matching: After not including statistics in last year’s report, ESMA has returned to provided information on pairing and matching. As a dual sided regulation, when both counterparties to a derivative are in scope, they both have an obligation to report their side of the trade using the same economic details and unique trade identifier (UTI). The matching details are among the DQI’s ESMA included in the report.
Prior to the REFIT, high levels of mismatches of UTIs and economic details led ESMA to highlight alignment among counterparties as one of the goals of the REFIT. In this regard, initial findings provide positive momentum. According to ESMA, among open UTIs on a Trade level where both counterparties had a requirement to report, as of December 2024, only 20.5% of derivatives didn’t have a matching UTI submitted from both parties. This compares to 33.91% in May 2024 and estimates of above 40% prior to REFIT. Position level UTIs also showed improvement with the REFIT and mismatched UTIs ended 2024 at 22.17% compared to 55.16% in May 2024.
Stale Valuations: Another key DQI that ESMA has noted in previous data quality reports are outstanding derivatives where an updated valuation was missing. 2024 ended with 16.19% of UTIs being flagged as missing a valuation update. While this figure improved from nearly 30% in the middle of the year, it was still higher than the 12.2% mark revealed by ESMA at the end of 2023.
Abnormal Maturities: After including it as an area of focus in last year’s report, ESMA provided statistics on abnormal maturities that were flagged. The figure ranged between 10-16% in 2023 but declined to around 10-12% over 2024.
Entity Responsible for Reporting Errors: A new DQI under EMIR with this year’s report are incorrect values for the Entity Responsible for Reporting field. The field was added to EMIR with the REFIT after it had previously been introduced by ESMA in 2021 for SFTR. According to ESMA, as of December 2024, 1.36% of eligible records included incorrect data for this field. ESMA stated that although the DQI was below their general 5% threshold, it was included in the report as the field is viewed as a “crucial addition under EMIR REFIT”.
