Updated EMIR Refit and SAP Trade repository reporting: are you ready? 

March 2024
3 min read

SAP Treasury’s Strategy for Seamless Compliance worldwide

In the first half of 2024, European treasurers are confronted with a new item on their agenda: the updated EMIR Refit. The new EMIR reporting rules will be implemented in the EU on the 29th of April 2024, and in the UK on the 30th of September 2024.  

The Updated EMIR Refit introduces the following main changes: 

  • Harmonizing the reporting formats to ISO 20022 XML 
  • Increasing the number of reporting fields from 129 to 203 (204 in the UK) 
  • Introducing new fields: UPI (Unique product identifier) and RTN (Report Tracking Number) 

For more details about these changes, refer to this article on the implications of the EMIR Refit

Trade repository reporting in SAP Treasury and Risk management 

SAP Treasury users inquire on how to deal with the changes in their solution, what comes out of the box, what adjustments are necessary,and where the challenges are.  

Since the introduction of the original EMIR reporting in 2012, SAP has covered the requirements for EMIR reporting in the component Trade repository reporting. It is a robust functionality fully integrated into the SAP Transaction manager environment. Due to varying requirements among the various trade repositories, SAP has ceased to enhance the solution and referred clients to the partner solution of Virtusa. However, the SAP Trade repository solution (“TARO”) is still supported on all current releases in the existing functional extend and can be used and adopted by in-house developments and consulting partners (SAP Note 2384289). Using the Virtusa solution or a custom solution, with EMIR Refit, a number of new required fields needed to be incorporated into the deal management data model.  

The following changes have been provided by individual SAPNotes over the course of the past months: 

  • Unique Product Identifier (ISO 4914 UPI) and Report Tracking Number (RTN) have been introduced. They are available under the tab “Administration” in the deal data. 
  • These fields have been introduced to the relevant BAPIs, mirror deal functionality, as well as to the SAP TPI interface.  
New reporting fields 

The EMIR Refit solution utilizes fields, which have already been made available earlier, over the course of the original EMIR Refit in 2018 (Switch FIN_TRM_FX_HMGMT_3), and are present also under the tab “Administration” for the relevant product categories:  

  • CFI Code (Classification of Financial Instruments, ISO 10692 Classification) 
  • ISIN on the deal level for OTC deals 
  • Market Identification Code (MIC) 

The recently introduced field is the UPI, which is a classification assigned by ANNA Derivatives Service Bureau. It consists of 12 characters and reflects both the Asset class, Instrument type, Product and the CFI. The CFI itself is an instrument classification which is 6 characters long. 

 The next consideration is how to populate these fields. In case of external trades, the CFI and UPI can be delivered by the trading platform. SAP Trade platform integration (TPI) covers the transfer of these fields from the trading platforms.  

Since 2019, in case of OTC deals, EMIR Refit made financial counterparties (FC) solely responsible and legally liable for reporting on behalf of both counterparties, provided the non-financial counterparty is below the clearing threshold (NFC-). Therefore, this option would be necessary only for large financial entities, as smaller corporates are not obliged to report external OTC deals, as the counterparty reports on their behalf.  

Corporates are obligated  to report their intercompany deals, under the condition that they cannot apply for an opt out with their regulator. In that case, the CFI and UPI need to be derived in-house.  

For that purpose, there are enhancements (BAdIs) available, to implement one's own derivation logic.  

The reporting format has been standardized with ISO 20022 based XML. XML output can be easily generated based on a DMEE structure. Unlike the original version from 2012, SAP does not deliver the new report structures needed for the EMIR Refit. This part needs to be set up in a project.  

The impact of the EMIR Refit in the trade repository reporting of your organisation can bring up many specific questions. We are happy to help you answer them from both the advisory as well as the technical implementation point of view. Examples on how Zanders can assist is: 

  • Implementing the new Emir Refit requirements in SAP Treasury 
  • Assisting in applying for the exemption of reporting internal trades with the various regulators 

Reach out to Michal Šárnik to receive assistance on this topic. 

SAP and Zanders: In partnership we trust

March 2024
3 min read

SAP Treasury’s Strategy for Seamless Compliance worldwide

Our technology partnerships are core, foundational elements of our risk and treasury transformations at Zanders. For us to guide our clients through their digitalization journeys and keep pace with technology advancements relies on the right relationships (non-commercial of course, so we maintain our independence) with the best solution providers in our field. To stand the test of time, these relationships need to be mutually advantageous, and this takes both parties to be engaged, committed to continual learning, and driven by a shared vision. Our work with SAP embodies these qualities. And in demonstration of the success of this alliance, in 2024 we’re celebrating 25 years of partnership with the market-leading technology platform.  

To mark this anniversary milestone, we invited Christian Mnich, VP, Head of Solution Management, Treasury and Working Capital Management at SAP to join Zanders partners Judith van Paassen and Laura Koekkoek to reflect on how the relationship has developed in this time. As they shared anecdotes and considered the unique characteristics that have shaped this partnership, three key themes emerged – collaboration, trust, and growth.  

1. Collaboration: A meeting of minds 

From day one, there was an enthusiasm from both companies to collaborate and share expertise. Zanders’ first encounter with SAP was at a trade fair in 1998. Back then, Zanders was four years young and a relative newcomer to the treasury advisory world. SAP was an established standard in business processing software but at this point still a single-product, ERP solution. As the modern technologies lead for Zanders, Judith van Paassen visited the SAP stand at the exhibition curious to see how the platform could extend to support the work Zanders was doing with corporate treasury departments.  

“SAP was present at that fair with an early version (2.2F) of the system,” Judith recounts. “I asked some in depth questions at the time about functionalities. Can SAP do this? Can SAP do that? After some further discussion and exchange of knowledge, the idea to join forces was brought up.” 

On the basis of this trade fair encounter, SAP and Zanders together started looking into how the system could be customised for treasury, specifically at the time for the Dutch market. 

2. Trust: The backbone of successful partnership 

The partnership initially focused on the Netherlands, with Judith regularly spending time with SAP colleagues, working with the team on how to position the treasury system to the market and helping them to demonstrate the potential of the solution to support corporate treasury processes.  

“It was a very close partnership between the Netherlands and Zanders – where Zanders and SAP worked closely together and were organizing seminars to inform the market on the capabilities in SAP,” Christian remembers. “This model was very unique back then and the partnership model is still working very well for SAP and their partners.”  

These early days formed a backbone for the partnership, embedding a commitment to honest and open collaboration into the core of the relationship.  

“It’s all been built from trust,” Christian emphasizes. “When building a long-lasting partnership, you need to have open dialogue – on both sides. It’s very important to us as a solution provider that when we roll out new solutions, we get honest feedback. We’ve had lots of sessions with Zanders over the years where you’ve provided this honest feedback. By doing this, you’ve helped us to scale our solutions, develop new solutions and increase the adoption of our services.” “This also comes back in our co-development of regional solutions for local requirements like the connectivity between eBAgent and MBC in the APJ region” says Laura. 

3. Growth: Pioneering new environments

As the partnership has expanded from the Netherlands and Benelux to the UK, parts of the DACH region, the US and APJ, it has provided a launchpad for important growth opportunities for both businesses. For Zanders, it’s empowered our team with a much deeper understanding of the role and potential of innovation in our market, enabling us to take a proactive role in guiding our clients through transformation projects.  

“We’re consultants – we like to give advice to our clients – but we also really want to implement solutions with our clients,” says Judith. “To do this, we need to not only look at the little details within treasury, but at the end-to-end process and architecture. Our knowledge of treasury in combination with our experience with SAP technology has definitely made us more attractive to expand our services to clients in Asia, the US and APJ. It’s has also allowed us to take a more proactive role in driving large-scale treasury transformations for our clients.” 

Christian agreed that the partnership has also been an enabler of growth for SAP, highlighting three transformation projects undertaken jointly by the partnership as key moments:

  • Firstly, AkzoNobel. It was the first treasury transformation the partnership worked on where SAP was implemented to replace a best of breed TMS system in the European environment. The size and complexity of this project made it a blueprint for future transformations. In particular, demonstrating the benefits of breaking down product siloes to add treasury capabilities to the SAP ERP system in a more integrated way.  
  • Secondly, BP. Although not as large and extensive as other projects, it’s notable for its strategic importance. This project represented the first entry into the UK for SAP, paving the way into an important growth market and opening up new opportunities in other regions. 
  • Thirdly, the implementation of the SAP S/4HANA treasury system for Sony. As a truly global transformation project, the scale and nature of the project (especially given the timing with the pandemic) meant there were many challenges. The success of the deployment is a testament to the strength of the partnership, with the teams working together closely to develop the best solution for the client.

Together, these projects show the relentless commitment from both partners to challenge boundaries, see the bigger picture and prioritize client needs.  

“We’ve seen a willingness from Zanders to expand their view from core treasury into other areas,” Christian explains. “This is very important for us from an SAP point of view. Smaller, niche or more boutique partners – they don't leave their comfort zone, whereas there's always interest from Zanders to learn new things. We appreciate how you try to understand the challenges before your customers run into these challenges.”  

25 years – A celebration of collaboration, trust, and growth 

What our 25 years working with SAP shows us is the success of our partnership comes down to how we work together as a team. This means trusting each other, being collaborative, and relies on both parties being willing to challenge the status quo to pursue ambitious growth. What SAP and Zanders have accomplished together already may have been ground-breaking, but it feels like we’ve still only just scratched the surface of what we can potentially achieve together. For this reason, our journey together will continue long into the future – at pace. 

Post-implementation challenges – mitigating the risks of a new Treasury landscape 

December 2023
3 min read

SAP Treasury’s Strategy for Seamless Compliance worldwide

But what happens after implementation, when the project team has packed up and handed over the reins to the employees and support staff? 

The first months after a system implementation can be some of the most challenging to a business and its people. Learning a new system is like learning any new skill – it requires time and effort to become familiar with the new ways of working, and to be completely comfortable again performing tasks. Previous processes, even if they were not the most efficient, were no doubt second nature to system users and many would have been experts in working their way through what needed to be done to get accurate results. New, improved processes can initially take longer as the user learns how to step through the unfamiliar system. This is a normal part of adopting a new landscape and can be expected. However, employee frustration is often high during this period, as more mental effort is required to perform day-to-day tasks and avoid errors. And when mistakes are made, it often takes more time to resolve them because the process for doing so is unfamiliar. 

High-risk period for the company 

With an SAP system, the complexity is often great, given the flexibility and available options that it offers. New users of SAP Treasury Management Software may take on average around 12 – 18 months to feel comfortable enough to perform their day-to-day operations, with minimal errors made. This can be a high-risk period for the company, both in terms of staff retention as well as in the mistakes made. Staff morale can dip due to the changes, frustrations and steep learning curve and errors can be difficult to work through and correct. 

In-house support staff are often also still learning the new technology and are generally not able to provide the quick turnaround times required for efficient error management right from the start. When the issue is a critical one, the cost of a slow support cycle can be high, and business reputation may even be at stake. 

While the benefits of a new implementation are absolutely worthwhile, businesses need to ensure that they do not underestimate the challenges that arise during the months after a system go-live. 

Experts to reduce risks 

What we have seen is that especially during the critical post-implementation period – and even long afterward – companies can benefit and reduce risks by having experts at their disposal to offer support, and even additional training. This provides a level of relief to staff as they know that they can reach out to someone who has the knowledge needed to move forward and help them resolve errors effectively. 

Noticing these challenges regularly across our clients has led Zanders to set up a dedicated support desk. Our Treasury Technology Support (TTS) service can meet your needs and help reduce the risks faced. While we have a large number of highly skilled SAP professionals as part of the Zanders group, we are not just SAP experts. We have a wide pool of treasury experts with both functional & technical knowledge. This is important because it means we are able to offer support across your entire treasury system landscape. So whether it be your businesses inbound services, the multitude of interfaces that you run, the SAP processes that take place, or the delivery of messages and payments to third parties and customers, the Zanders TTS team can help you. We don’t just offer vendor support, but rather are ready to support and resolve whatever the issue is, at any point in your treasury landscape. 

As the leading independent treasury consultancy globally, we can fill the gaps where your company demands it and help to mitigate that key person risk. If you are experiencing these challenges or can see how these risks may impact your business that is already in the midst of a treasury system implementation, contact Warren Epstein for a chat about how we can work together to ensure the long-term success of your system investment. 

Driving Treasury Innovation: SAP Digital Currency Hub 

December 2023
3 min read

SAP Treasury’s Strategy for Seamless Compliance worldwide

In this article, we explore this stablecoin payments trial, examine the advantages of digital currencies and how they could provide a matching solution to tackle the hurdles of international transactions.  

Cross-border payment challenges 

While cross-border payments form an essential part of our globalized economy today, they have their own set of challenges. For example, cross-border payments often involve various intermediaries, such as banks and payment processors, which can result in significantly higher costs compared to domestic payments. The involvement of multiple parties and regulations can lead to longer processing times, often combined with a lack of transparency, making it difficult to track the progress of a transaction. This can lead to uncertainty and potential disputes, especially when dealing with unfamiliar payment systems or intermediaries. Last but not least, organizations must ensure they meet the different regulations and compliance requirements set by different countries, as failure to comply can result in penalties or delays in payment processing. 

Advantages of digital currencies 

Digital currencies have gained significant interest in recent years and are rapidly adopted, both globally and nationally. The impact of digital currencies on treasury is no longer a question of ‘if’ but ‘when, as such it is important for treasurers to be prepared. While we address the latest developments, risks and opportunities in a separate article, we will now focus on the role digital currencies can play in cross-border transactions.  

The notorious volatility of traditional crypto currencies, which makes them less practical in a business context, has mostly been addressed with the introduction of stablecoins and central bank digital currencies. These offer a relatively stable and safe alternative for fiat currencies and bring some significant benefits. 

These digital currencies can eliminate the need for intermediaries such as banks for payment processing. By leveraging blockchain technology, they facilitate direct host-to-host transactions with the benefit of reducing transaction fees and near-instantaneous transactions across borders. Transactions are stored in a distributed ledger which provides a transparent and immutable record and can be leveraged for real-time tracking and auditing of cross-border transactions. Users can have increased visibility into the status and progress of their transactions, reducing disputes and enhancing trust. At a more advanced level, compliance measures such as KYC, KYS or AML can be directly integrated to ensure regulatory compliance. 

SAP Digital Currency Hub 

Earlier this year, SAP launched its Digital Currency Hub as a pilot to further explore the future of cross-border transactions using crypto or digital currencies. The Digital Currency Hub enables the integration of digital currencies to settle transactions with customers and suppliers. Below we provide a conceptual example of how this can work. 

  1. Received invoices are recorded into the ERP and a payment run is executed. 
  2.  The payment request is sent to SAP Digital Currency Hub, which processes the payment and creates an outgoing payment instruction. The payment can also be entered directly in SAP Digital Currency Hub. 
  3. The payment instruction is sent to a crypto exchange, instructing to transfer funds to the wallet of the supplier. 
  4. The funds are received in the supplier’s wallet and the transaction is confirmed back to SAP Digital Currency Hub.  

In a second example, we have a customer paying crypto to our wallet: 

  1. The customer pays funds towards our preferred wallet address. Alternatively, a dedicated wallet per customer can be set up to facilitate reconciliation. 
  2. Confirmation of the transaction is sent to SAP Digital Currency Hub. Alternatively, a request for payment can also be sent. 
  3. A confirmation of the transaction is sent to the ERP where the open AR item is managed and reconciled. This can be in the form of a digital bank statement or via the use of an off-chain reference field. 

Management of the wallet(s) can be done via custodial services or self-management. There are a few security aspects to consider, on which we recently published an interesting article for those keen to learn more

While still on the roadmap, SAP Digital Currency Hub can be linked to the more traditional treasury modules such as Cash and Liquidity Management or Treasury and Risk Management. This would allow to integrate digital currency payments into the other treasury activities such as cash management, forecasting or financial risk management. 


With the introduction of SAP Digital Currency Hub, there is a valid solution for addressing the current pain points in cross-border transactions. Although the product is still in a pilot phase and further integration with the rest of the ERP and treasury landscape needs to be built, its outlook is promising as it intends to make cross-border payments more streamlined and transparent. 

A guide to optimize SAP Treasury business partner design and maintenance 

December 2023
3 min read

SAP Treasury’s Strategy for Seamless Compliance worldwide

Additionally, business partners are essential in SAP for recording information related to securities issues, such as shares and funds. 

The SAP Treasury Business Partner (BP) serves as a fundamental treasury master data object, utilized for managing relationships with both external and internal counterparties across a variety of financial transactions; including FX, MM, derivatives, and securities. The BP master data encompasses crucial details such as names, addresses, contact information, bank details, country codes, credit ratings, settlement information, authorizations, withholding tax specifics, and more. 

Treasury BPs are integral and mandatory components within other SAP Treasury objects, including financial instruments, cash management, in-house cash, and risk analysis. As a result, the proper design and accurate creation of BPs are pivotal to the successful implementation of SAP Treasury functionality. The creation of BPs represents a critical step in the project implementation plan. 

Therefore, we aim to highlight key specifics for professionally designing BPs and maintaining them within the SAP Treasury system. The following section will outline the key focus areas where consultants need to align with business users to ensure the smooth and seamless creation and maintenance of BPs. 

Structure of the BPs: 

The structure of BPs may vary depending on a corporation's specific requirements. Below is the most common structure of treasury BPs: 

Group BP – represents a parent company, such as the headquarters of a bank group or corporate entity. Typically, this level of BP is not directly involved in trading processes, meaning no deals are created with this BP. Instead, these BPs are used for: a. reflecting credit ratings, b. limiting utilization in the credit risk analyzer, c. reporting purposes, etc. 

Transactional BP – represents a direct counterparty used for booking deals. Transactional BPs can be divided into two types: 

   - External BPs – represent banks, financial institutions, and security issuers. 

   - Internal BPs – represent subsidiaries of a company. 

Naming convention of BPs 

It is important to define a naming convention for the different types of BPs, and once defined, it is recommended to adhere to the blueprint design to maintain the integrity of the data in SAP. 

Group BP ID: Should have a meaningful ID that most business users can understand. Ideally, the IDs should be of the same length. For example: ABN AMRO Group = ABNAMR or ABNGRP, Citibank Group = CITGRP or CITIBNK. 

External BP ID: Should also have a meaningful ID, with the addition of the counterparty's location. For example: ABN AMRO Amsterdam – ABNAMS, Citibank London – CITLON, etc. 

Internal BP ID: The main recommendation here is to align the BP ID with the company code number. For example, if the company code of the subsidiary is 1111, then its BP ID should be 1111. However, it is not always possible to follow this simple rule due to the complexity of the ERP and SAP Treasury landscape. Nonetheless, this simple rule can help both business and IT teams find straightforward solutions in SAP Treasury. 

The length of the BP IDs should be consistent within each BP type. 

Maintenance of Treasury BPs 

1. BP Creation: 

Business partners are created in SAP using the t-code BP. During the creation process, various details are entered to establish the master data record. This includes basic information such as name, address, contact details, as well as specific financial data such as bank account information, settlement instructions, WHT, authorizations, credit rating, tax residency country, etc. 

Consider implementing an automated tool for creating Treasury BPs. We recommend leveraging SAP migration cockpit, SAP scripting, etc. At Zanders we have a pre-developed solution to create complex Treasury BPs which covers both SAP ECC and most recent version of SAP S/4 HANA. 

2. BP Amendment: 

Regular updates to BP master data are crucial to ensure accuracy. Changes in addresses, contact information, or payment details should be promptly recorded in SAP. 

3. BP Release: 

Treasury BPs must be validated before use. This validation is carried out in SAP through a release workflow procedure. We highly recommend activating such a release for the creation and amendment of BPs, and nominating a person to release a BP who is not authorized to create/amend a BP.  
BP amendments are often carried out by the Back Office or Master Data team, while BP release is handled by a Middle Office officer.  

4. BP Hierarchies: 

Business partners can have relationships as described, and the system allows for the maintenance of these relationships, ensuring that accurate links are established between various entities involved in financial transactions. 

5. Alignment: 

During the Treasury BP design phase, it is important to consider that BPs will be utilized by other teams in a form of Vendors, Customers, or Employees. SAP AP/AR/HR teams may apply different conditions to a BP, which can have an impact on Treasury functions. For instance, the HR team may require bank details of employees to be hidden, and this requirement should be reflected in the Treasury BP roles. Additionally, clearing Treasury identification types or making AP/AR reconciliation GL accounts mandatory for Treasury roles could also be necessary.  

Transparent and effective communication, as well as clear data ownership, are essential in defining the design of the BPs. 


The design and implementation of BPs require expertise and close alignment with treasury business users to meet all requirements and consider other SAP streams.  

At Zanders, we have a strong team of experienced SAP consultants who can assist you in designing BP master data, developing tools to create/amend the BPs meeting strict treasury segregation of duties and the clients IT rules and procedures. 


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