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If a block trade gives rise to multiple transactions, each transaction would have to be reported. Specifically, exempt entities under Article 1 4 are exempt from all obligations set out in EMIR, while exempt entities under Article 1 5 are exempt from all obligations except the reporting obligation, which continues to apply. Subsequently the application of the Article 1 4 exemption was extended to include the central banks and debt management offices of the United States and Japan.

The Commission has indicated that further foreign central banks and debt management offices may be added in the future if they are satisfied that equivalent regulation is put in place in those jurisdictions. Article 1 5 broadly exempts the following categories of entities: - Multilateral development banks; - Non-commercial public sector entities owned and guaranteed by central government; and - The European Financial Stability Facility and the European Stability Mechanism.

The contract is to be identified by using a unique product identifier. In addition, a unique trade identifier will be required for transactions. The LEI will be used for the purpose of reporting counterparty data. A LEI is a unique identifier or code attached to a legal person or structure, that will allow for the unambiguous identification of parties to financial transactions. For the purpose of calculating whether a clearing threshold has been breached, an NFC must aggregate the transactions of all non-financial entities in its group and determine whether or not those entities are inside or outside the EU but discount transactions entered into for hedging or treasury purposes.

What must be reported and when: Information must be reported on the counterparties to each trade counterparty data and the contracts themselves common data. There are 26 items that must be reported with regard to counterparty data, and 59 items that must be reported with regard to common data. What has to be reported and who is responsible for reporting: Reporting applies to both OTC derivatives and exchange traded derivatives.

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