{ "tool_id": "art-576-emir3-active-account-representativeness-classifier", "tool_version": "1.0.0", "display_name": "EMIR 3.0 Active Account Representativeness Classifier", "mcp_name": "classify_emir3_active_account_status", "mandate_type": "compliance_mandate", "wave": 97, "gpu": false, "url": "https://ainumbers.co/chaingraph/art-576-emir3-active-account-representativeness-classifier.html", "description": "Classifies an EU counterparty's posture under EMIR Article 7a (the Active Account Requirement, inserted by Regulation (EU) 2024/2987) across three obligations: whether the active-account obligation applies and is met at an Article-14-authorised CCP; whether the Article 7a(4) representativeness obligation applies, is exempt below the EUR 6 billion notional-clearing-volume threshold, or is met by clearing at least five trades on an annual average basis in each caller-declared most-relevant subcategory per class; and whether a reporting submission falls within the applicable Commission Delegated Regulation (EU) 2026/305 Article 10 window (last day of January or July, first cycle anchored to the stated 2026-07-31 report). Subcategories are bucketed deterministically from caller-declared trade size and maturity against the RTS Annex I tables for EUR fixed-to-float, OIS and FRA, PLN fixed-to-float and FRA (single any/any bucket), and EUR STIR Euribor and euro short-term rate. Which subcategories are ESMA's market-wide most-relevant designation is not derivable from one counterparty's own trades and is taken as a caller-declared input, named in the artifact's not_proven list. Each obligation resolves to MET, NOT_MET, EXEMPT, or INDETERMINATE, and INDETERMINATE covers every case where a required input -- clearing-threshold exceedance, active-account status, notional volume, subcategory designation, or reporting date -- was not declared; none is guessed toward a passing verdict. Cites Article 7a EMIR and Commission Delegated Regulation (EU) 2026/305, re-verified against EUR-Lex at build. Existing EMIR coverage on this site is trade-report field, lifecycle, UTI and UPI validation only; this is a distinct Active Account Requirement self-check, not a duplicate. Stated boundary: this is not legal advice, and does not independently verify that a declared trade actually cleared or that the counterparty genuinely exceeds the Article 4a clearing threshold.", "input_schema_ref": "chaingraph/art-576-emir3-active-account-representativeness-classifier.html#manifest", "consumes": [], "feeds": [], "status": "live", "conformance_fixtures": true, "compute_capability": "server", "compute_images": [ { "system": "sha256-source", "image_id": "sha256:61ccaaf1ba92ae118685760e5c4c2d2196095b159dd005a1e79d115d31e544c6", "valid_from": "2026-07-10" }, { "system": "risc0", "image_id": "sha256:a1a0bc89b5b1febaeda3519f6dbade0fa5ac16beeb143c4e1b01689573567bc6", "valid_from": "2026-08-07" } ], "export_capability": [ "json" ], "compute_proof_ready": "ready", "deferred_reason": "New shard; awaiting the async GPU proving queue (S18 steady-state).", "compute_proof": { "type": "ZkVmReceipt", "system": "risc0", "receiptFormat": "groth16-bn254", "imageId": "sha256:a1a0bc89b5b1febaeda3519f6dbade0fa5ac16beeb143c4e1b01689573567bc6", "seal": "K6XeDqSShocPrkhoPsooohve/62boBIrkRmnPMYfGegiWEN0+zJp/9g6Z8FhgrpD/aNSS78EVnpCRs3UbMhI6www39l5ei1FRqPnquvIdKOJiCoBb36cCsnarVu9jPNPDHS4GqjLmEu4f2jMWP0rZ6XtbVmqsKenVdr8E5S5Ur8PI1Xs6jIK3bQxBUwqch6TkKpeT00adWXuzVr0Aay4UAJWoz3lxc9FctEmB3O8gEzHgVfGXiB4xQKM8VG7wm44H4cwqR/gAwMQYa+rLsy9BWgP03ikS6lzUmTgZ879wKEXeDJAQUys1AsJGYzUVWG9QaXmAYG/Tl3eFHoL1nc0lg==", "journal": { "chaingraph_version": "0.4.0", "kernel_digest": "sha256:61ccaaf1ba92ae118685760e5c4c2d2196095b159dd005a1e79d115d31e544c6", "output": { "as_of_date": "2026-08-07", "bucket_counts": {}, "citations": { "active_account_obligation": { "detail": "An in-scope counterparty shall hold at least one active account at an Article-14-authorised CCP for the categories in paragraph 6 (EUR/PLN interest rate derivatives; EUR short-term interest rate derivatives).", "source": "Article 7a(1) and 7a(6) EMIR (inserted by Regulation (EU) 2024/2987)" }, "reporting_window": { "detail": "Reports are due on the last day of January and the last day of July each year. The first submission falls no earlier than six months from the RTS entry into force of 2026-02-26; the spec states the first report as the dated fact 2026-07-31.", "source": "Commission Delegated Regulation (EU) 2026/305, Article 10" }, "representativeness_test": { "detail": "Counterparties above the threshold shall clear, on an annual average basis, at least five trades in each of the most relevant subcategories per class of derivative contracts and per reference period.", "source": "Article 7a(4) EMIR" }, "representativeness_threshold": { "detail": "The representativeness obligation does not apply to counterparties with a notional clearing volume outstanding below EUR 6 billion in the paragraph-6 derivative contracts.", "source": "Article 7a(4) EMIR" }, "subcategory_tables": { "detail": "Defines the size/maturity subcategory bucketing tables per class: EUR fixed-to-float, OIS, FRA (Article 4); PLN fixed-to-float and FRA, single any/any bucket (Article 5); EUR STIR Euribor and euro short-term rate, maturity-only buckets (Article 6).", "source": "Commission Delegated Regulation (EU) 2026/305, Articles 4-6 and Annex I" } }, "counterparty_ref": "SYNTH-CP-001", "fence": "This is not legal advice and is not an ESMA or CCP determination. The most-relevant subcategory designation per class is taken as a caller-declared fact; this kernel does not compute it from market-wide data. Whether a declared trade genuinely cleared, and whether the counterparty genuinely exceeds the Article 4a clearing threshold, are asserted by the caller, not independently verified.", "in_scope": { "eur_pln_ird": false, "eur_stir": false }, "not_proven": [ { "detail": "This kernel classifies an Article 7a active-account and representativeness posture from caller-declared facts. It is not a substitute for counsel, ESMA, or the counterparty's own compliance review.", "item": "Not legal advice" }, { "detail": "Which subcategories are the class's ESMA-designated \"most relevant\" ones for a reference period is a market-wide volume ranking published externally, not derivable from one counterparty's own trades. This kernel takes it as a caller-declared fact (subcategory_designations[].most_relevant) and does not verify it against any external source.", "item": "Most-relevant subcategory designation" }, { "detail": "A trade count over a reference period shorter than 12 months is annualized by simple linear scaling (count * 12 / reference_period_months). This is a documented simplification, not a seasonally-aware estimate.", "item": "Annualization is a linear simplification" }, { "detail": "Whether a declared trade was in fact cleared at an authorised CCP, and its size/maturity/class classification, are caller-supplied and asserted, not independently verified against a CCP or trade repository record.", "item": "Trade-level \"cleared\" status is asserted" }, { "detail": "Whether the counterparty exceeds the Article 4a EMIR clearing threshold for each category is a caller-declared boolean, not independently recomputed here.", "item": "Clearing-threshold exceedance is asserted" } ], "note": "Deterministic EMIR Article 7a Active Account Requirement posture classification for one stated point in time. Single-run and stateless: it holds no records, runs on no schedule, and retains nothing.", "obligations": { "active_account": { "reason": "Neither in-scope category (Art 7a(6)(a) EUR/PLN IRD, (b) EUR STIR) is declared as exceeding the clearing threshold, so the Article 7a(1) active-account obligation does not apply.", "verdict": "EXEMPT" }, "reporting_window": { "applicable_deadline": "2027-01-31", "reason": "No in-scope category is declared as exceeding the clearing threshold, so no RTS Article 10 reporting obligation applies.", "reference_period_end": "2027-01-31", "reference_period_start": "2026-07-31", "reporting_submission_date": null, "verdict": "EXEMPT" }, "representativeness": { "notional_clearing_volume_minor_units": null, "reason": "No in-scope category is declared as exceeding the clearing threshold, so the Article 7a(4) representativeness obligation does not apply.", "subcategory_results": [], "threshold_minor_units": 600000000000, "verdict": "EXEMPT" } }, "rationale": [ "EMIR Article 7a Active Account Requirement posture classified for counterparty reference SYNTH-CP-001 as of 2026-08-07.", "In-scope categories: EUR/PLN interest rate derivatives = false, EUR short-term interest rate derivatives = false (Article 7a(6)).", "Active-account obligation (Article 7a(1)): EXEMPT. Neither in-scope category (Art 7a(6)(a) EUR/PLN IRD, (b) EUR STIR) is declared as exceeding the clearing threshold, so the Article 7a(1) active-account obligation does not apply.", "Representativeness obligation (Article 7a(4)): EXEMPT. No in-scope category is declared as exceeding the clearing threshold, so the Article 7a(4) representativeness obligation does not apply.", "Reporting window (RTS Article 10): EXEMPT. No in-scope category is declared as exceeding the clearing threshold, so no RTS Article 10 reporting obligation applies.", "1 supplied value was not usable and was treated as absent or excluded, never silently guessed toward a MET/EXEMPT verdict. Each one is named in rejected_inputs.", "This is not legal advice. The most-relevant subcategory designation per class is a caller-declared fact, not derived from market-wide data this kernel does not have access to; whether a trade genuinely cleared is likewise asserted, not independently verified." ], "rejected_inputs": [ { "reason": "absent or not a positive integer", "supplied": null, "where": "reference_period_months" } ], "subcategory_designations": [], "trades_classified": [] } } } }