EMT v3 – New features and changes from EMT v1

On 10^th of December 2019, the European Working Group validated the new EMT (European MiFID template) v3 template. A few important changes have been made compared to EMT v1, the version currently used by investment funds. The changes include updates from existing EMT v1 fields as well as additional new fields.

What is the implementation timeline?

A 1-year transition period had been recommended from validation date, i.e. from 10^th of December 2019 until 10^th of 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 soon as 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 version 3.

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 & Needs
  • Reference date is date of setup or validation of the Target Market
• Impacting Costs & Charges :
  • Reference date of the data required for ex-post and for ex-ante
  • Borrowing costs should now be disclosed (ex-ante & ex-post)

How Deloitte can help?

• Based on our experience with over 200,000 EPT & EMT documents produced & disseminated on a yearly basis, we offer our clients a specialized and integrated service offering dedicated to EPT & 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 at 10^th of December 2019
  

Official communication from FinDatEx: https://extranet.findatex.eu/news/36/findatex-published-mifid-template-version-3-0