Cappitech EMIR REFIT Update – Specs, Working Groups, Integrations and UAT
As we start the new year, Cappitech is hard at work preparing for the upcoming EMIR REFIT changes. We wanted to share a behind the scenes view of what we are doing to help our clients and the industry prepare for the upcoming changes.
One of the last pieces of business for ESMA in 2022 was their publishing of the Final Report Guidelines for EMIR REFIT (link) at the end of December. With the go-live date of April 29th 2024 being set by ESMA in October, the Final Report provided the key validation rules needed to formalize specifications for the updated REFIT technical standards.
Reporting Specifications & Gap Analysis
At Cappitech, we were eagerly waiting for the Final Report to be published. After creating a comprehensive reporting specification file of EMIR fields, values, descriptions, and validation rules, we recently produced our version of the technical specification for reporting. (Final technical specifications may change minimally following the publishing of specifications from Trade Repositories. However, the current version gives firms a head start in preparing and planning for their own implementations.) Firms can contact us to receive our reporting specification file to assist their preparation for the report updates.
Cappitech is actively working to support our existing clients through a thorough gap analysis on new reporting requirements and comparisons between existing and new fields. In addition, clients will have access to our enhanced version of the reporting specifications which cover mapping of old to new values of changed fields and logic calculations. Overall, our aim is to simplify the uplift for clients and to recycle existing data integrations and file extracts they are using for their current EMIR reporting and automatically convert it for REFIT.
Integrations and UAT
As a next step from sharing our specifications, we are currently building our UAT environment for EMIR. The major Trade Repositories (TR) have indicated expectations to launch their UAT environments to support REFIT between May to October of this year. Cappitech fully expects to be live with UAT to meet the TR timetables and provide three quarters of end-to-end submission testing capabilities. In cases where a customer’s desired TR hasn’t yet launched its UAT environment, firms can still leverage Cappitech’s testing features to process submission files which are converted to ISO 20022 XML and run through ESMA’s validation requirements.
As an early adopter of the REFIT specifications, new customers onboarding this year with Cappitech have the option to integrate simultaneously with the current EMIR and upcoming REFIT technical specifications. This feature allows firms to ‘integrate once’ and go live now with current EMIR this year and easily migrate to the REFIT in 2024 when it goes into effect.
Elsewhere, client education continues. As the end of 2022 we kicked off our client Working Groups. These forums allow us to focus on a number of key topics and how REFIT is impacting clients and create a wider audience discussion. Areas being covered are event type/lifecycle changes, product specific gap analysis, challenges of FCA divergence, updating open positions to the REFIT and the new unique product identifier (UPI) field (more on these topics available on our blog).
Webinars & Industry Events
Cappitech remains focused on providing relevant, timely and engaging thought leadership content through webinars, breakfast briefings, forums and industry events related to the EMIR REFIT.
If you’d like to join our client events (open to both existing clients and interested parties), please get in touch with our team. Our next webinar will be running January 25th (link to register).
We’ve also started working groups on an industry solution focused on the sharing and paring of UTIs called UTI Connect. Cappitech (through legacy IHS Markit) launched a similar service under the SFTR requirements utilized by the vast majority of the industry. More information on the solution and to sign up to the network can be found here.
Future proofing regulatory change is a critical component of a comprehensive reporting solution and we at Cappitech pride ourselves at ensuring our clients stay up to date with all regulatory change, minimize the technical operational impact when those changes do happen and create forums where the industry can come together to solve complex issues impacting all of us.