FinDatEx publishes the European MiFID Template Version 3 (EMT V3)


FinDatEx publishes the European MiFID Template Version 3 (EMT V3)

12 December 2019

Regulatory News Alert

On Tuesday 10 December 2019, FinDatEx validated the new EMT (European MiFID template) v3 template. A few important changes have been made to EMT v1, the version currently used by investment funds, which include updates from existing EMT v1 fields as well as additional new fields.


What is the implementation timeline?

A one-year transition period had been recommended from validation date, i.e. from 10 December 2019 until 10 December 2020. During this period, manufacturers may provide both EMT v1 and EMT v3 to their distributors.


What does it mean for asset managers?

Some distributors have mentioned their intention to request the new EMT v3 as of the beginning of 2020, while others have mentioned their intention to wait until mid-2020 or until the end of the transition period. In order to meet different distributors’ requirements, Deloitte recommends disseminating both v1 and v3 of the EMT throughout the entire transition phase, until all your distributors have switched to the latest version.


What has changed from EMT v1?

  • Impacting all EMT fields:
    • Some conditional fields have been transitioned to ‘mandatory’
    • Some fields have a change in naming for clarification purposes
    • A reference date should be indicated for each part of the EMT and reflect the period for which the data is applicable.
  • Impacting EMT static data:
    • Information on reporting ‘producer’ is introduced
    • Financial Instrument product type has more detailed classifications
    • Share class types are better identified with new flags for performance fee, distribution, or payment of distribution
    • In order to align better with German market requirements, compliance with MiFID II product government has been added.
  • Impacting EMT target market:
    • ESG is now a dedicated field of ‘client objectives and needs’
    • Reference date is date of setup or validation of the ‘target market’.
  • Impacting costs and charges :
    • Reference date of the data required for ex-post and for ex-ante
    • Borrowing costs should now be disclosed (ex-ante and ex-post).


How Deloitte can help?

  • Based on our experience with over 200,000 EPT and EMT documents produced and disseminated on a yearly basis, we offer our clients a specialized and integrated service offering dedicated to EPT and EMT reporting requirements
  • We can help perform a data gap analysis of EMT v1 and EMT v3 based on your current operating model
  • We can produce both EMT v1 and EMT v3 repots during the full transition period, starting as of 10 December 2019


Official communication from FinDatEx:


Xavier Zaegel
Partner – Capital Markets/Financial Risk Leader
Tel: +352 45145 2748

Sylvain Crépin
Partner – Capial Markets/Financial Risk
Tel: +352 45145 4054

Lou Kiesch
Partner – Regulatory Consulting Leader
Tel: +352 45145 2456

François-Kim Hugé
Partner – Fund Registration Services
Tel: +352 45145 2483

Benoit Sauvage
Director – RegWatch, Strategy & Consulting
Tel: +352 45145 4220

Florence Buron
Director – Financial Industry Solutions
Tel: +352 45145 2704

Julien Baguet
Senior Manager – Capital Markets/Financial Risk
Tel: +352 45145 4609



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