ISDA published guidance on how implementation of the 2021 Interest Rate Definitions may impact regulatory transaction reporting.

In the guidance, ISDA clarified that trades reported before October 4, 2021 (and using the 2006 ISDA Definitions) will not need any data modifications and, therefore, will not require re-reporting. Following implementation of the 2021 Definitions, "the majority" of EMIR and MiFID II fields are expected to be reported as before. The exceptions may include:

  • for EMIR, the "Floating Rate of Leg 1" and the "Floating Rate of Leg 2" fields; and
  • for MiFID II, the "Underlying index name" field,

which may be populated with different values.

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