In the EMIR Review Report no. 4 of 13 August 2015 - ESMA input as part of the Commission consultation on the EMIR Review (2015/1254 the European Securities and Markets Authority (ESMA) recommends substantial modification to the EMIR reporting requirement i.e. waiving the obligation to report contracts which were terminated before the reporting start date (i.e. 12 February 2014).
Proposed amendment to Article 9(1) of Regulation (EU) No 648/2012 (second paragraph) is as follows:
The reporting obligation shall apply to derivative contracts which:
(a) were entered into before 12 February 2014 and remain outstanding on that date, or
(b) were entered into on or after 12 February 2014.