A counterparty to a derivative that fulfils the conditions set out in point (a) or (b) of Article 2(2) on XX.XX.20XX or the entity responsible for reporting shall report all details of that derivative required in accordance with the Annex by submitting a report with event type ‘Update’ within 180 calendar days of the [PO please insert date of application of the ITS], unless they have submitted a report with the action type ‘Modify’ or ‘Correct’ for that derivative within this period.