Newsletter on market conduct, transaction reporting issues and UK EMIR reporting.
September 2025
About this edition
In September 2024, we and the Bank of England (the Bank) made changes to the UK EMIR reporting regime. These changes, referred to as UK EMIR Refit, are part of an effort to make derivatives reporting more transparent and improve the quality of data firms report to trade repositories (TRs). The changes also aimed to align the UK's derivatives reporting framework with international standards to support greater global consistency, where appropriate.
High-quality data is essential for both us and the Bank to monitor for systemic and financial stability risk. For example, UK EMIR data has played a pivotal role in analysing the use of critical benchmarks across commodities and rates markets, directly informing firm outreach and policy development. We also rely on this data during periods of volatility. Following April’s tariff announcements, we used OTC SONIA Swaps activity, enhanced by MiFID transaction data for other products, to build a clearer picture of participants’ rates exposure.
In this Market Watch, we look at UK EMIR Refit one year on. We share our observations on implementation, change and vendor management. These are based on our supervisory work, data analysis and feedback we have received from the joint FCA and Bank of England UK EMIR Reporting Industry Engagement Group. We also look at UK EMIR errors and omissions notifications. Our aim is to support the reporting of more accurate and complete data.
Firms with an obligation to report derivatives under Article 9 of UK EMIR (counterparties) should consider how this publication aligns with their existing processes and reporting frameworks. They should also consider the Reporting Q&As published by us and the Bank.
This work will also be of interest to firms subject to UK SFTR and UK MiFID transaction reporting requirements. The points about change management may be relevant to firms more generally that are undertaking regulatory change projects.
UK EMIR Refit implementation
Following the implementation of UK EMIR Refit, reporting counterparties were required to report details of new derivative contracts in line with the new requirements. There was also a 6-month transition period for counterparties to update outstanding derivative trades entered into before 30 September 2024.
This transition period ended on 31 March 2025. By the end of the transition period, 95% of reports had been successfully uplifted. This is illustrated in Chart A. We thank counterparties for their significant effort to meet this deadline.
We observed counterparties taking different approaches to ensure compliance with the new requirements. Some updated their entire population or specific asset classes on the first available reporting date. Others took a more staged approach throughout the transition period.
Most counterparties were able to report in line with the new format by the end of the transition period. However, a small number maintained a population of non-uplifted reportable trades past 31 March 2025 as shown in Chart B. This counterparty maintained a large population of non-uplifted trades as of 31 March 2025 when the strict schema came into effect. From this point, these non-uplifted trades could no longer be reported, and the counterparty breached their reporting obligation.
We expect all counterparties to uplift all eligible trades as soon as possible to re-establish compliance with their reporting obligation.
Change management
Counterparties and TRs had more than 18-months’ notice of the new EMIR requirements. Although over 95% of reports were compliant as of 28 March 2025, 4.81% of trades on the trade state report were not uplifted before the end of the transition period.
We have also identified that 19% of counterparties encountered some challenges with reporting following Refit implementation, and 1.45% of UK reporting counterparties have failed to report details of derivative trades entirely since the new requirements came into effect. These issues materially affect our visibility of the UK derivatives market, and our ability to monitor for systemic risk and get insight from the data.
We have observed two main drivers for the problems counterparties faced with Refit implementation in the UK:
Inadequate resource planning
Some counterparties did not appropriately plan their resource needs ahead of implementation. Others encountered problems due to key person dependencies when progressing their project plans.
These issues manifested in delays to system testing, late discovery of issues and insufficient time to resolve issues ahead of the implementation deadline. When issues occurred, some counterparties were proactive in informing us of the challenges they faced. However, a significant proportion failed to engage with us when they identified material challenges that put delivery at risk.
Firms should plan and assign appropriate resources to change management activities to ensure they are able to meet compliance dates for instances of regulatory change. This includes ensuring there are clear policies and procedures in place, as well as effective change-related documentation.
Dependence on external vendors
We have seen an increase in counterparties using third party vendors to help with reporting. An analysis of UK third party vendors via the ‘Report Submitting Entity ID’ field (Table 1, Field 2) shows many of these vendors have increased their daily reporting volumes significantly post-Refit. Some have doubled the number of daily trade reports they submit on behalf of counterparties.
However, in some cases, vendors were unable to adequately support their clients in meeting the implementation date due to limited resource and clients competing for priority.
Reporting counterparties can use the services of a vendor to either submit reports on their behalf or to enrich their data. However, the obligation to ensure that reported data is complete and accurate remains with the counterparty.
We have seen instances of poor-quality reports submitted by vendors on behalf of counterparties. Root causes include inaccuracies in vendors’ data mapping, enrichment and schema logic.
Firms undertaking regulated activity should have appropriate systems and controls to ensure they comply with their regulatory obligations. When using vendors to support regulatory reporting, this means counterparties being able to ensure that any reports submitted on their behalf are complete and accurate.
If counterparties have material issues with the accuracy, completeness or timeliness of their reported data caused by their vendor, the entity responsible for reporting is required to notify us by submitting a breach notification.
This section should be read in conjunction with the observations we made in Market Watch 81.
Errors and omissions management
Since UK EMIR Refit go-live on 30 September, we have received breach notifications corresponding to 267 distinct reporting issues. This number is lower than we would expect. We analysed trading volumes, peer submissions and comparisons to notifications made against UK MiFIR transaction reporting, where appropriate. The volume of notifications we have received may be partially attributable to counterparties having different governance thresholds and criteria for what constitutes a material breach of UK EMIR. However, we do not consider this is a sufficient rationale to justify the low volume of breach notifications we have received.
Where central counterparty clearing houses (CCPs) identify material errors or omissions in reported data, they should submit notifications to the Bank. All other counterparties subject to Article 9 of UK EMIR should submit notifications to us using the notification form on our webpage.
The entity responsible for reporting is required to notify us of any material issues with their reported data as soon as it becomes aware of the issue. Notifications should be comprehensive, including adequate background to enable a full review of the incident. If more information becomes available, firms can update us by emailing [email protected] referencing their original breach notification.
We expect firms to have effective procedures in place to evaluate incidents and determine when to submit a breach notification.
As set out in the notification form, it is for counterparties to determine when an identified breach is sufficiently material to require reporting to us. Where counterparties are uncertain about the materiality of a given error, they should notify us.
We are increasing our monitoring of the breach notifications we receive now that Refit implementation is complete, with a focus on volume, quality and timeliness.
The observations in this Market Watch should be read in conjunction with Market Watch 82.
Next steps
As UK EMIR Refit continues to embed, our priority for the next 12 months is to improve overall data quality. To do this we will:
- Continue to work closely with industry to support more accurate and complete reporting. The reporting of high-quality data is essential in enabling us and the Bank to effectively monitor for systemic and financial stability risk.
- Increase our focus on reconciliation rates.
- Closely monitor breach notifications and actively engage with firms that fail to meet our expectations.
- Assess counterparties’ systems and controls to ensure they are reporting accurately. This includes being able to correct errors across both live and matured trades.
Counterparties should consider these workstreams and take steps to assure themselves that they have appropriate arrangements in place for each.
Our Reporting obligation webpage gives further information on UK EMIR reporting. Please send any questions to [email protected].