According to ESMA, “counterparties should follow their local time to determine the day on which the derivative was concluded, modified or terminated. The deadline for reporting is the working day following that day. The determination of the deadline for reporting in the local time does not affect the way in which the relevant dates and times (such as execution timestamp) are reported to the TRs.” Thus, for two counterparties to the same transaction where they are located in different time zones, each counterparty will follow its own local calendar and use its own local time to determine the deadline for reporting. This is as far as concerning the determination of the deadline of reporting. In regards to reporting to the TRs, as per the Commission Delegated Regulation (EU) 2017/105, time convention for reporting is defined as UTC (Coordinated Universal Time).
In regards to public holidays, counterparties are not obligated to report a transaction done the day before. The deadline for reporting is the working day following the day the transaction was concluded.
For Example:
| Transaction Date | Country | Public Holiday | Report On | Can be delayed |
| 2020-12-24 | GB | 2020-12-25 (Yes) 2020-12-28 (Yes) |
2020-12-29 | 5 days |
| 2020-12-31 | GB | 2021-01-01 (Yes) | 2021-01-02 | 2 days |
| 2020-05-29 | DE | 2020-06-01 (Yes) | 2020-06-02 | 4 days |
| 2020-11-10 | FR | 2020-11-11 (Yes) | 2020-11-12 | 2 days |
References
- COMMISSION IMPLEMENTING REGULATION (EU) 2017/105 of 19 October 2016. [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=:32017R0105&from=EN]
- Q&A Implementation of the Regulation (EU) No 648/2012 on OTC derivatives,central counterparties and trade repositories (EMIR), 24 September 2020. [https://www.esma.europa.eu/sites/default/files/library/esma70-1861941480-52_qa_on_emir_implementation.pdf]
