I’m not sure if Aprils Fools and spending the first day of April each year playing practical jokes on each other is a western concept or whether it’s more universal and embraced by our Asian friends and colleagues.
Even if it’s more universally adopted I struggle to picture serious national regulators engaging in Aprils Fools pranks. It’s hard to picture the UK’s FCA releasing a statement on the morning of 1 April saying they are about to repeal MiFID II and then adding in the afternoon, ‘Gotcha, April Fools!’.
I’m pontificating about this because 1 April 2024 is starting to look pretty interesting for the APAC transaction reporting regimes. As it stands here at Kaizen Reporting we’re tracking several reporting timelines starting to coalesce around this date.
- In Japan the JFSA have a consultation on their proposed changes due in July 2022. Implementation of these changes which will include harmonising to CDE (critical data elements), UPI (unique product identifier) and UTI (unique transaction identifier) – all being widely adopted by other global regulators – is expected to be implemented on 1 April 2024
- Down under in Australia, ASIC have taken a slightly different approach with a small batch of changes due on 1 October 2023. These will then be followed by the main event (harmonisation to CDE, UPI, UTI etc) being implemented on 1 April 2024
- The HKMA in Hong Kong also has a consultation on CDE & UPI due second half of 2022. Implementation of these changes along with adopting of collateral and margin reporting is currently slated for “no sooner than 1 April 2024”
- Over in Singapore MAS is keeping us guessing as it is reviewing the responses received from their recent consultation on harmonisation including CDE, UPI and UTI. At the time of writing they haven’t published firm dates but a 2024 go-live is looking very likely.
And as if that wasn’t plenty to keep the regulatory transaction reporting community busy that’s just the APAC side of things.
- In Europe the European Commission has finally approved the EMIR Refit RTS which assuming the EU parliament sticks with its allocated three months to pass the Refit into law then points towards a late Q1 to early Q2 2024 go live
- Over in Canada the CSA authorities released a consultation on 8 June that also sees the Canadians wanting to get in on the CDE, UPI, UTI harmonisation party and they too are proposing – you guessed it – a 2024 implementation.
And finally closer to home for me, the UK Treasury and FCA are pointing towards a summer policy statement that should clarify the implementation timeline for the UK version of the EMIR Refit. Here at Chez Kaizen we’re tracking late 2024 for the UK Refit but I guess it’s not too late for the FCA to go for April Fools Day 2024!
- Kaizen can help firms prepare for the regulatory changes mentioned above. For a conversation with Alan or one of our regulatory specialists, please contact us.