Under EMIR, both counterparties must ensure that data related to concluded trades (as well as counterparty data relating to the entities involved in the trades) are reported to the relevant repositories. Unlike Dodd Frank, however, all derivatives contracts (including both OTC and exchange-traded derivatives) must be reported, as well as lifecycle events (give-ups and terminations). Firms have until the working day following the trade to meet this requirement, so many challenges lie ahead in ensuring the quality and accuracy of this counterparty data so that it can be delivered in a timely manner.