On 13 March 2020, the ISDA published a document that captures some of the operational considerations and potential steps financial counterparties and non-financial counterparties may need to take in order to adhere to the EMIR Refit requirement – as of 18 June 2020, financial counterparties will be legally liable for the timely and accurate reporting of over-the-counter derivatives contracts on behalf of both themselves and their non-financial counterparty minus clients.
