Unique Product Identifier: Crypto-asset identifiers
Unique Product Identifier: Crypto-asset identifiers As we had discussed in previous blog entries regarding the UPI and the technical data on how to generate the UPI, we now turn our focus on a specific aspect of the UPI. UPI for derivatives on crypto-assets. As mentioned in our January blog entry, ANNA-DSB has adopted various standards widely accepted by industry stakeholders. E.g. ANNA DSB adopted the following standards: for currencies the three letter ISO 4217 code; for Securities their ISIN, or SEDOL, or CUSIP, or FIGI; for Equity Indices, their ISIN or official name as published by the index administrator; etc. Crypto assets represent a particular problem, due to their nature they are not standardised nor are they issued with any unique identifier. As such, crypto-asset jargon widely used to identify such assets is not standardised nor unique, e.g. bitcoin is sometimes referred to BTC or XBT, while Ethereum Ether, is sometimes referred to as Ether, ETH or with Greek letter Xi Ξ. In order to avoid duplication pitfalls, for crypto-asset identifiers, ANNA-DSB has decided to adopt the identifiers issued by the Digital Token Identifier Foundation – DTIF. The code is a unique 9 letter code that characterizes each crypto asset maintained and issued by the aforesaid foundation. See below a non-exhaustive list of crypto-assets with their corresponding DTIF code. [table id=Token_DTIFs /] As such entities that want to generate or retrieve UPIs on crypto-assets derivatives, they should, be aware of the appropriate identifier of the underlying reference value (the crypto asset) in this case the crypto-asset DTIF code. For a comprehensive list of the DTIF codes that ANNA DSB has included in its libraries refer to the link here. See also a short list of issued UPIs on the basis of the above. [table id=Token_DTIFS_UPI /] *Disclaimer, the DTIF codes and the Unique Product Identifiers in this blog are presented for information purposes only, for an up-to-date list of DTIF codes and/or UPIs consult Digital Token Identifier Foundation and/or ANNA – DSB resources. How is MAP FinTech going to assist? MAP Fintech offers the UPI Link Service that helps retrieving companies match their products’ attributes precisely to those already issued UPIs, ensuring that reporting companies use the correct UPI Code. MAP FinTech’s UPI Link Service boasts essential functionalities, including: Automated identification of UPIs using reference data provided by the reporting entity and the latest issued UPIs supplied by the ANNA-DSB. UPI enrichment of reported files prior to submission to the TR. Error identification where UPIs cannot be mapped against the ANNA-DSB’s issued UPI records. Inline editing capability for on-the-fly amendments on the UPI. Advanced search function from within Polaris portal which can pinpoint the exact UPI based on enhanced search criteria.
MAP FinTech Webinar – In anticipation of the EU EMIR REFIT launch
MAP FinTech hosted a webinar with its EMIR-obliged clientele a few days before the REFIT go-live date to better prepare reporting entities. MAP FinTech staff reiterated to reporting entities that, when reporting on a delegation basis on behalf of other financial institutions (such as investment firms, credit institutions, funds etc.) defined under EMIR as Financial Counterparties (FCs), they need to furnish their Trade Repositories (TRs) with the LEI and a contact email for the said FCs. Trade Repositories need to obtain explicit authorisation by delegating parties As per the requirements of EMIR REFIT, TRs will need to directly contact delegating parties asking them to confirm in writing that they have authorised the reporting entities to submit EMIR reports on their behalf. Failure by the delegating parties to provide explicit confirmation will result in the rejection of reports submitted by report-submitting entities on their behalf. TRs have begun reaching out to delegating parties from early April 2024 and urged reporting entities to inform all those concerned to take prompt actions. Finally, for non-financial counterparties for whom the reporting entities are liable to submit EMIR reports on their behalf, the reporting entities can self-certify that they have received the authorisation to report without the need for the TR to directly obtain the explicit confirmation. UPI population status update On the issue of generating UPIs, MAP FinTech informed reporting entities that as per ANNA-DSB, the authority issuing UPIs, as of early March 2024 about 1,148,000 UPI records were generated. However, from an analysis conducted by ANNA-DSB, only 300,000 were generated by Market Participants; the rest were populated by ANNA-DSB themselves from the record they have of OTC unlisted derivatives that were issued with an ISIN. It was emphasised to webinar attendees that a UPI must be available on the reporting day. Therefore, attendees must examine their OTC derivatives’ offerings and try to identify the suitable UTI from ANNA-DSB’s database. In cases where the necessary UPI does not exist, reporting entities need to generate it. You can refer to MAP FinTech’s blog on the technical aspects regarding the generation of a UPI. Testing of the new regime MAP FinTech readiness and troubleshooting MAP FinTech informed the audience that it has carried out extensive testing of the new reporting regime and has identified discrepancies and inconsistencies in the XML schema and ESMA’s validation rules that caused reporting breaks. These were addressed to the TRs and ESMA who have provided intermediate guidance on how to overcome these issues. Furthermore, MAP FinTech informed clients that, as of the beginning of April the overwhelming majority of its clientele had already provided the necessary additional data for the REFIT reporting regime and those were successfully incorporated into the new reports and were tested in a UAT TR environment. New tools for EMIR-REFIT In closing, participants were reminded that MAP FinTech offers new tools to assist its clientele, namely the UPI Link search tool that identifies issued UPIs from ANNA-DSB’s database, and XMLCon.Vert service that allows clients to convert .csv files to the requisite REFIT XML format. MAP FinTech: your trusted RegTech Provider Looking ahead, MAP FinTech pledges continuous monitoring and support post-launch, anticipating an adjustment period and committing to random reconciliation checks to uphold data integrity. Clients are urged to vigilantly monitor submissions and report any anomalies during the initial weeks. As the countdown to this pivotal milestone accelerates, the synergy between MAP FinTech, clients, and TRs assumes paramount importance. With unwavering dedication to facilitating a seamless transition, MAP FinTech expresses gratitude for the collective effort of all stakeholders, confident that this complex undertaking will ultimately yield more efficient reporting processes under the new EMIR REFIT standards. At MAP FinTech, we offer more than just cutting-edge technology; We provide expert knowledge and unwavering support to guarantee a seamless transition to the new reporting requirements. Contact our team of experts today and experience a smooth transition.
Is the DIY of EMIR REFIT a Costly Detour?
The world of financial regulations is constantly evolving, and it is crucial for businesses to stay compliant with these rapidly changing rules. One such regulation is the European Market Infrastructure Regulation (EMIR) and its many reporting requirements. Understanding EMIR REFIT Reporting The upcoming changes to EMIR reporting were drafted to harmonise the reporting regimes with the work being carried out at an international level by IOSCO-CPMI on critical derivatives’ elements. There are several changes that the new regime ushers in, including more granular data submitted, new fields, changes to fields that are carried over from the current EMIR reporting regime, new outgoing messages from TRs to reporting entities as well as regulators such as abnormal values, outdated valuations and so on, and the introduction of the UPI, among others. Crucially, the new regime increases the number of data points and values that are subject to reconciliations, which have now expanded to include, for example, valuations. While all the lessons learned with the original iteration of EMIR will not be altogether scrapped, the new reporting regime introduces its own complexities. Hence, reporting counterparties need to be prepared to hit the ground running from the reporting start date as there is no grace period involved. This creates an acute need for reporting entities to enhance their Information Technology, Risk and Compliance capabilities in order to fully digest the substantial body of standards, guidance, and rules issued by the regulators for EMIR REFIT. Can EMIR REFIT Reporting Be Done In-house? Many reporting entities consider implementing EMIR REFIT reporting in-house for reasons such as greater control over sensitive financial data, flexibility, immediate cost savings, and resource reusability. However, it’s crucial for any organization considering an in-house solution to evaluate the real costs and missed opportunities associated with this choice. Financial Cost Parameters of DIY EMIR REFIT Reporting The financial cost associated with self-implementing EMIR REFIT reporting encompasses a spectrum of elements, including human resources expenses, reporting fees, technology-related costs, and the effort required, among others. Human Resources cost: The diverse roles required for in-house EMIR REFIT reporting lead to substantial personnel- related costs, including salaries, training, recruitment, and administrative expenses. The types of professionals required to run this kind of solution internally may include: Regulatory Analysts IT Business Analysts Software Developers Infrastructure Architects Quality Assurance Experts UI/UX Experts Project Managers Talent acquisition and retention challenges have become more prominent than ever, making assembling an in-house team a complex and costly endeavor. Partnering with specialised service providers can alleviate these issues and ensure efficient and compliant reporting. Reporting fees: Choosing to contract directly with a Trade Repository (TR) for EMIR REFIT reporting rather than using a third-party aggregator can result in higher reporting costs. This cost disparity is primarily attributed to the fee bands associated with trade reporting. When a third-party aggregator is involved, it can accumulate a larger volume of trade data, reaching higher fee bands more quickly. This increased volume allows the aggregator to benefit from economies of scale, resulting in a more favorable price per trade, with the potential to pass on this financial benefit to the reporting entities. Consequently, companies contracting directly with TRs may find themselves paying comparatively higher fees due to the aggregation advantage held by aggregators and service providers in the reporting process, including when it relates to EMIR REFIT. Technology cost: Choosing to tackle EMIR REFIT reporting entails bearing the full brunt of technology costs, which may encompass expenses related to software licenses, hardware and infrastructure, as well as security measures. In contrast, opting for a specialized service provider often provides a more cost-effective option. They can leverage their existing infrastructure, software resources, and security protocols, ultimately reducing the company’s financial burden. One example when it comes to EMIR REFIT is the expertise and effort needed to migrate from the current CSV files that are currently used to the newly introduced XML template following the ISO 20022 methodology. Once again, the economies of scale achieved through service providers can significantly lower technology expenditures when compared to attempting to manage these complexities independently. Effort required: Undertaking EMIR REFIT reporting internally necessitates a significant investment of time across multiple phases. During the Preparation phase, a considerable number of hours is needed to conduct a thorough gap analysis to identify the required changes. Subsequently, moving into the Design and Implementation phase, there’s a substantial time commitment linked to tasks such as integrating new fields, adhering to recently introduced ISO standards, mapping Unique Product Identifiers (UPIs), converting files from CSV to XML formats, integrating additional action types within trading systems, and handling various related activities. Following this, the Quality Assurance phase demands a considerable amount of time to ensure that the changes meet the criteria of completeness, accuracy, and adherence to specified timelines. As the reporting deadline approaches, meticulous planning and execution become imperative during the Migration and Go-Live phases to prevent last minute issues and ensure a seamless transition to the new reporting requirements, such as, for example, the updating of outstanding trades. Last but not least, a commonly underestimated phase is the one of Post-implementation, which necessitates plenty of time to establish and maintain the required monitoring mechanisms and procedures. Overall, the entire in-house EMIR REFIT reporting process is a time-intensive endeavor that typically spans from eight to twelve months for completion. Other financial costs: Costs related to the continuous monitoring of the regulatory landscape and other opportunity costs are incurred when opting for in-house reporting. Maintenance costs escalate due to the need for continuous monitoring of the complex and ever-changing regulatory landscape, requiring substantial hours for compliance updates. For example, in EMIR REFIT, the reconciliation process will be conducted in two phases: 87 fields in the go-live phase, and 61 fields two (2) years after. Furthermore, there’s an opportunity cost involved as valuable hours and resources are redirected from revenue-generating endeavors. As per Deloitte’s recent global outsourcing survey, “Enabling focus on core functions” is the most common perceived benefit among companies that use outsourcing. Other
What are the key regulatory developments to keep an eye on in H1?
An insightful article in FinTech Global highlights several key regulatory developments to watch in the financial landscape during the first half of 2024. Key areas of focus include communication compliance, with continued scrutiny of recordkeeping accuracy and the monitoring of communication channels. Additionally, the rise of Generative AI (GenAI) brings both promise and regulatory attention, as authorities seek to address compliance implications associated with AI technologies. Further regulatory efforts are anticipated in areas such as cryptocurrency regulation, with a focus on stablecoins and cross-border compliance. Additionally, as noted by Christodoulos Mouskos, Head of Operations at MAP FinTech, the changes under EMIR REFIT will introduce new derivatives reporting requirements, presenting initial challenges for reporting parties as they adapt to the new rules and collaborate with regulatory bodies to address inconsistencies. Overall, the regulatory landscape is poised for continued evolution, with an emphasis on harmonisation across jurisdictions and alignment with emerging technologies. Firms are advised to stay proactive in implementing compliance measures to navigate these regulatory shifts effectively. Read the full article here. Contact our team of experts and learn how you can benefit from our innovative and comprehensive regulatory reporting solutions.
How will the new EMIR REFIT reporting requirements impact the EU and the UK markets?
In a recent article published by FinTech Global, George Markides, Senior Manager of the Compliance Support Department at MAP FinTech, highlights key aspects of the new EMIR REFIT reporting regime and how it will impact the EU and UK markets. The rules come into effect on April 29, 2024, in Europe and September 30, 2024, in the UK. According to Markides, the regime introduces several novelties that will impact the way reporting counterparties operate and exchange information with each other, inviting increased scrutiny from regulators. Notably, Markides writes that one of the most significant changes is the additional data points and values reported that will be subject to reconciliation for dual-sided reports submitted by counterparties in the EEA or UK. The reconciliation takes place at the trade repository (TR) level with results shared with reporting entities and regulators. Crucially, valuations of derivative contracts under EMIR will also be subject to reconciliation. Markides emphasises the establishment of the Unique Product Identifier (UPI), a concept introduced in EMIR V1 but now required from day one of the new reporting regime. UPI serves as an identifier for non-listed OTC derivatives and is issued by ANNA Derivatives Services Bureau (ANNA-DSB), though new issuances will incur fees. Additionally, EMIR REFIT introduces more detailed outgoing messages from TRs, sharing data such as number of submissions, number of rejections, outstanding positions, and trades with outdated or no valuations or collateral information, reconciliation status, or abnormal values reported. These reports aid reporting entities in correcting their submissions and provide regulators with a more immediate and comprehensive view of compliance with the reporting regime. In conclusion, Markides stresses that these changes necessitate reporting counterparties to enhance oversight and monitoring to minimise potential lapses in compliance. Read the full article here. MAP FinTech can fully assist any firm under EMIR Reporting to seamlessly adapt to the evolving reporting requirements brought on by EMIR REFIT. Contact our team of experts and learn how you can benefit from our innovative and comprehensive regulatory reporting solutions.
EU/UK EMIR REFIT: A Significant Increase to the Number of Reportable Fields
Partner Up with MAP FinTech to Overcome Your Challenges With deadlines approaching for implementing the new EMIR reporting standards in the EU (April 29, 2024) and the UK (September 30, 2024), it is crucial to fully understand these new requirements and what they entail. Based on these new standards, there has been a significant expansion in the number of relevant fields with them increasing from 129 to 203 in the EU and 204 in the UK. Considering the removal of 13 fields, this means the introduction of 87 new fields in the EU and 88 in the UK. Moreover, approximately 100 fields have undergone modifications in terms of their name, description, acceptable values, or a combination of these factors. Overall, this increase in the number of fields poses a significant challenge and could potentially burden reporting entities. For instance, they now face the task of locating new fields, sourcing the necessary information, and incorporating them into their regular reporting cycle. Among the new field additions, one that should have a substantial impact is the introduction of the “Event Type” field. While the “Action Type” field addresses the “What” aspect of a transaction, the “Event Type” field delves into the “Why” aspect, offering greater granularity to the event’s lifecycle. When combined, these two fields, “Action Type” and “Event Type,” results in 56 distinct and permissible combinations of values, which in turn significantly alters the lifecycle event management and necessitates specific actions within the entity’s reporting system. These actions are necessary in order to capture these events accurately and seamlessly and incorporate the changes into the reporting workflow, enabling their automatic reporting when the relevant conditions are met. An indicative short list of EMIR REFIT’s newly introduced field-related changes can be found below: Unique Product Identifier (UPI) obligations Crypto-asset-related derivative flag Post Trade Risk Reduction (PTRR) related fields New Action Type values Event Type field Delta The new fields mandated under the updated ITS/RTS, both individually and collectively, pose a distinctive challenge for firms. As previously mentioned, this challenge is multifaceted, starting with identifying and localizing these fields, extending to their acquisition, and ultimately incorporating them seamlessly into the reporting cycle. Furthermore, the increase in the number of EMIR REFIT fields compounds the complexity of an already complicated task, one that includes coordination between reporting counterparties to ensure the accurate completion of these fields to prevent unnecessary pairing and matching issues. In addition, if not handled correctly, this increase may result in an elevated risk of receiving more rejections from Trade Repositories (TRs) and failures to match, given that with the new RTS/ITS additional fields will be reconciled by TRs. Moreover, firms will now have to deal with larger incoming and outgoing files (the more fields, the bigger and more complex the file becomes), introducing additional overheads in terms of processing resources, storage requirements, and the level of complexity when working with these files. At MAP FinTech, we are well-equipped to help you with these challenges. Firstly, we can provide valuable guidance in understanding which reportable fields are relevant to your specific trading model and activity. Furthermore, we offer flexibility in terms of how this information is retrieved or received from the reporting entity, ensuring the seamless integration of data. Our approach to the increase in the number of fields involves requesting only the necessary information from the reporting entity, while employing conditional rules and enhancement criteria to complete the remaining required fields. This facilitates the reporting process and reduces the burden on the reporting entity. Furthermore, our Polaris web portal (the interface of our Polaris reporting platform) offers an efficient solution for managing fields that do not change very often (the so-called static information). This user-friendly portal simplifies the task for reporting entities, making field management as straightforward as possible. Also, our reporting algorithms are designed to automatically identify relevant actions taking place in the client’s trading system or data and map them to the appropriate action and event types in reporting, thus providing substantial assistance to the reporting entity to overcome this challenge. Lastly, thanks to the numerous validations incorporated into our Polaris reporting platform, potential rejections are caught at an early stage within the reporting system before they reach the TRs and the National Competent Authorities (NCAs). This proactive approach ensures that, despite the increase in the number of fields, reporting firms will maintain a healthy reporting framework and remain compliant at all times. Partner Up with MAP FinTech to Overcome Your Challenges MAP FinTech is a leading and award-winning global regulatory technology provider, highly regarded for its proprietary reporting technology and exceptional client-centric after-sales support. As one of the first providers in Europe to report under the European Market Infrastructure Regulation (EMIR), with billions of transactions reported successfully so far, we have built a reputation for excellence, coupled with the necessary regulatory expertise and technological innovation to help navigate their respective regulatory obligations. Contact our team of experts to learn how you can benefit from our innovative and comprehensive regulatory reporting solutions and achieve a smooth transition to the changes in reporting requirements brought by EMIR REFIT.
Navigating the Challenges and Risks of Complying with CRS and FATCA Reporting Obligations
The objective of the Foreign Account Tax Compliance Act (FATCA) is to enhance tax compliance among US citizens through a comprehensive set of regulations. This legislation mandates foreign financial institutions to determine if their clients are “US persons” and provide the US Internal Revenue Service (IRS) with information on their financial accounts. Non-compliance with these regulations may lead to substantial penalties. The Common Reporting Standard (CRS), akin to FATCA, also aims to counter offshore tax evasion and upkeep the transparency of the global tax system. Financial institutions operating in participating jurisdictions are obligated to identify the tax residencies of their clients and disclose financial accounts held by foreign tax residents to the local tax authorities. These authorities then exchange this information with the relevant jurisdictions’ tax authorities. The time for yearly FATCA and CRS reporting is either near or already underway in some jurisdictions. Here are the deadlines for several of these. Challenges One of the major challenges faced by firms is the analysis and interpretation of the requirements, which consist of over 300 pages of guidelines to read. Additionally, completing more than 65 fields per record and dealing with complicated multilevel XML files can also pose a significant barrier. Moreover, managing different jurisdictions, each with its own unique set of intricacies, can be quite complex. Risks In terms of risks, incorrect completion of CRS and FATCA reporting, as well as failing to meet the reporting deadline and its many requirements, can result in penalties, reputational damage, and legal consequences. Investing a costly number of resources to file the relevant submissions, which may burden your budget and disrupt your daily operations, is another risk. Lastly, making incorrect or false submissions can result in withholding penalties for specific payments. How can MAP FinTech assist you? Given the complexity of FATCA and CRS reporting, the challenges in keeping up with the regulatory updates, and the penalties in case of non-compliance, it is reasonable to get ready early. MAP FinTech can fully support your business’ regulatory reporting needs. We receive reportable information, construct the CRS and FATCA annual reports, and, for most countries, submit them to the relevant competent authority as prescribed by the relevant provisions of both CRS and FATCA. ΜΑΡ FinTech’s CRS and FATCA Reporting Services provide a user-friendly approach to receiving, validating, transforming and submitting the relevant information required under CRS/FATCA reporting and due diligence rules. These services are delivered via our powerful and award-winning Polaris platform, together with the rest of its reporting offerings and our team of experts’ impeccable support services. ΜΑΡ FinTech’s CRS/FATCA – Key Features Cost-efficient integrated reporting solutions provided under a single platform. Highly automated and scalable solution that can report for as many accounts as you have. Flexible in the way it receives data, either via standard templates or raw data. Multiple reporting health checks for both content and schema and automatic filtering of erroneous entries. Automatic conversion of data to XML and separation of files based on tax residency. Submissions to various tax authorities worldwide. On-going communication with regulators to ensure the system reports reflect regulatory updates and changes.
EMIR reporting 101 – Collateral Updates
Did you know that Investment Firms, Banks, and Funds must report collateral received from clients including retail clients, or posted to other counterparties? Under EMIR’s risk mitigation techniques, Counterparties that do not clear their derivatives trades with a Clearing House, are required to exchange collateral to manage default/counterparty risk. This exchange of collateral must be reflected in the EMIR reporting that Counterparties submit to the TRs. Collateral is split under EMIR in three broad categories: Initial margin (received from clients/other counterparties or posted to other counterparties) Variation margin (received from clients/other counterparties or posted to other counterparties) Excess collateral Whereby Initial margin is the collateral collected to cover current and potential future exposure in the interval between the last collection of margin and the liquidation of positions or hedging of market risk following a default of the other counterparty Variation margin is the collateral collected to reflect the results of the daily valuations of outstanding contracts (either marked to market or marked to model) Excess collateral is additional collateral posted or received separately and independently from initial and variation margins At MAP FinΤech we can help create and submit on-time accurate collateral reports reflecting your trading data, with our dedicated support and compliance teams we can help counterparties navigate successfully and with ease the requirements under EMIR. Say goodbye to the hassle and hello to peace of mind with MAP FinTech. Contact us today to learn more!
UK EMIR Derivatives Reporting Framework: FCA update
On 24th February 2023, the FCA issued an update regarding changes to the UK EMIR derivatives reporting framework. The joint FCA/Bank of England Policy Statement (PS 23/2) announced that the new rules will come into force from 30 September 2024, as well as publishing draft versions of EMIR Validation Rules and Incoming/Outgoing XML schema. Firms can submit feedback for technical specification documents until the 24th of March 2024, with the final versions expected to be released shortly after this date. Although the UK rewrite remains largely in line with ESMA, there are some differences to be aware of: Dual Reporting Obligations Dates: With the ESMA deadline date on 29th April 2024, separate to the FCA 30 September 2024 date, firms with dual reporting obligations will need to provide two versions of EMIR reporting. Delegated Reporting: Regarding cross-jurisdiction reporting, EU entities currently providing delegated reporting to customers in the UK will continue to provide this in the existing format for clients but will need to use the updated Refit version internally. There is also additional pressure on UK firms providing delegation to EU firms, as they will need to be compliant by the earlier ESMA date of 29th April 2024 rather than the September deadline. Field and Validation Discrepancies: ‘Execution Agent’ is an additional field allowing third parties to be tagged by firms on their behalf. Various validations have been amended in the XML Schema Definitions (XSD) as well as a number of additional slight changes by the FCA. As the EU and UK frameworks continue to be updated in the future, it may become more difficult for firms to manage these discrepancies and requirements. Get in touch today to find out how we can assist your firm with the upcoming changes. How MAP FinTech may assist MAP FinTech is a leading award-winning global regulatory technology provider, highly regarded for its proprietary reporting technology and exceptional client-centric after-sales support. As one of the first providers in Europe to report under the European Market Infrastructure Regulation (EMIR), with billions of transactions reported successfully so far, we have built a reputation for excellence, coupled with the necessary regulatory expertise and technological innovation to assist firms in navigating their respective regulatory obligations. Contact our team of experts to find out how you can benefit from our innovative and comprehensive regulatory reporting solutions.
Regulation 2022 Roundup: The Calm Before the Storm?
MAP FinTech’s Senior Manager and Head of the Compliance Assurance Department, George Markides, offered his insights on the global regulatory reforms and challenges of 2022 in an article in Finance Magnates. Read the full article here. The article discusses, among others, the impact on brokers of several reforms and remarks made by the regulators, such as EMIR 2.0 – EMIR Refit and ASIC. Moreover, the article refers to the passporting regime of licenses in the European Union and what to expect in 2023 in terms of regulation.