Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
On 13 April 2026 ESMA published reporting templates and instructions for the Active Account Requirement under EMIR 3. They apply to entities subject to the AAR — including EU credit institutions and other in-scope financial and non-financial counterparties of London groups — and the reports go to national competent authorities, not to ESMA as the filing venue. ESMA says the first AAR reporting submission is “expected on 31 July 2026”, covering 25 June 2025, when the AAR became applicable, to 30 June 2026.
This is the countdown week. Subsequent filings are due on 31 January and 31 July each year, each covering a twelve-month reference period.
The AAR is an account-and-activity duty. Operations, clearing, collateral and regulatory-reporting teams have to produce a first pack covering more than twelve months of the requirement being applicable, using ESMA’s April templates, and lodge it with the NCA that supervises the counterparty.
London groups feel this on the EU entity, not on the UK parent. Clearing brokers that offer EU CCP access still have to make sure house and client accounts can generate the fields the templates ask for. If the first file is wrong, you repeat the error every 31 January and 31 July.
Operational consequences:
ESMA’s sentence is “expected on 31 July 2026”. Quote that word. Do not upgrade it to a different legal-instrument article, and do not hang the deadline on an Official Journal number that is not locked here.
| Business type | Why the 31 July file lands on you | What you file, and to whom | Official reference |
|---|---|---|---|
| EU credit institutions subject to the AAR | In-scope financial counterparty with clearing in the relevant derivative classes | First report to your NCA, using ESMA templates and instructions, covering 25 June 2025 – 30 June 2026 | ESMA 13/04/2026 news |
| Other in-scope EU financial counterparties | Same AAR population as ESMA describes (“entities subject to the AAR”) | Same templates; same NCA filing path | ESMA 13/04/2026 |
| In-scope EU non-financial counterparties of London groups | NFC status does not, by itself, take you out of ESMA’s AAR reporting population if you are subject to the AAR | Confirm classification and AAR scope before you decide not to file | ESMA 13/04/2026 |
| London / third-country parents | You do not file a UK AAR report under this ESMA note. You still have to resource the EU subsidiary or branch that does | Group evidence pack, CCP documentation, and NCA contact for the EU entity | ESMA 13/04/2026 (“report … to their competent authorities”) |
| EU clearing members / brokers | You hold the CCP account that clients may rely on as their active account | Account identifiers and the client-level data your clients will need for their NCA file | ESMA 13/04/2026 templates and instructions |
| NCAs | Receivers of the reports. ESMA published the templates to harmonise what you receive | Supervisory use of the 31 July pack and the six-monthly cycle thereafter | ESMA 13/04/2026 |
Operational tip: The first reference period is not a round year. It starts on 25 June 2025, not 1 July 2025, and it ends on 30 June 2026. A query written as “H2 2025 + H1 2026” drops the first five days.
| Step | Action | What operational staff must deliver | Official reference |
|---|---|---|---|
| 1 | Confirm who is subject to the AAR | Legal-entity list of EU counterparties in the group that must hold an active account. Exclude UK solo entities unless they are in ESMA’s population through an EU establishment | ESMA 13/04/2026 (“entities subject to the AAR”) |
| 2 | Freeze the first reference period | Data warehouse cut: 25 June 2025 through 30 June 2026. Reconcile to CCP statements for the same window | ESMA 13/04/2026 (“covering the period from 25 June 2025 … to 30 June 2026”) |
| 3 | Load ESMA’s April templates | Field-level mapping from internal clearing and collateral systems to the published templates and instructions | ESMA 13/04/2026 (“reporting templates and instructions”) |
| 4 | Identify the NCA and the channel | Named competent authority for each filing entity; portal or email path; authorised signatory. Do not send the file to ESMA | ESMA 13/04/2026 (“to their competent authorities”) |
| 5 | Reconcile account operability | Evidence that the active account existed across the period: CCP static data and activity logs from 25 June 2025 | ESMA 13/04/2026 (AAR “became applicable” 25 June 2025) |
| 6 | Internal sign-off before 31 July | Compliance, clearing ops and finance sign the pack. Diary ESMA’s wording: first submission expected on 31 July 2026 | ESMA 13/04/2026 |
| 7 | Stand up the repeating cycle | After the first file: submissions due on 31 January and 31 July each year, each covering a twelve-month reference period. Book 31 January 2027 and 31 July 2027 now | ESMA 13/04/2026 |
A short self-assessment covering AAR alongside clearing and reporting: EMIR / EMIR 3 Readiness Diagnostic.
GRT Consulting supports operational teams with:
Contact us for a focused first-report review: T: +44 20 3695 9251 E: info@grtconsult.com Web: grtconsult.com
Sources
