Recent Developments to UK EMIR Reporting Requirements

The regulatory landscape for derivatives reporting in the United Kingdom continues to evolve, with the Bank of England (BoE) and the Financial Conduct Authority (FCA) (together, the Regulators) actively refining the UK European Market Infrastructure Regulation (UK EMIR) framework. 

Two developments relating to UK EMIR reporting requirements were announced on 8 August 2025: 

• the publication of a joint BoE and FCA consultation (Consultation) on additional draft questions and answers (Q&As) for derivative reporting under Article 9 of UK EMIR; and
• the release of a BoE policy statement (Policy Statement) detailing amendments to trade repository (TR) reporting requirements. 

Consultation

The Consultation reflects the Regulators’ ongoing commitment to having access to derivatives data that is complete, accurate and consistent.

The Consultation seeks industry feedback on two key areas:

• Use of Technical ISINs. The Q&As clarify when it is permissible to use a technical International Securities Identification Number (ISIN) in derivatives reporting. Specifically, a technical ISIN may be used in the “underlying identification” field where a single stock equity that is the underlying of a reportable derivative is issued in a region that does not mandate the use of an ISIN and no ISIN is available, or if a pre-IPO single stock equity is the underlying of a reportable derivative. The technical ISIN may also be used if a custom basket of a reportable derivative transaction is composed entirely of constituents that are either not traded on a trading venue or do not have an available ISIN. The technical ISIN, however, should not be used to report the ISIN field.; and
• Reporting of FX Swaps. The Q&As address industry ambiguity regarding the reporting of foreign exchange (FX) swaps. The industry uses the term “FX swap” interchangeably to refer to two different transactions. Where an FX swap is concluded as two FX forward contracts (near and far legs) negotiated together, these should be reported as two separate reports, with relevant package transaction fields populated. The Consultation clarifies that only contracts within the package transaction that are subject to UK EMIR reporting obligations should be reported. If the transaction is a FX swap contract, it should be reported within a single report.

The draft Q&As are intended to be read alongside the Regulators’ February 2023 policy statement and supporting documentation such as the UK EMIR reporting Q&As. 

The Consultation closes on 12 September 2025. The Regulators expect to publish the finalised Q&As in October 2025. 

Policy Statement

Separately, the BoE has published the Policy Statement summarising the outcome of the Regulators’ June 2025 consultation on amendments to the UK EMIR TR reporting requirements. 

The Policy Statement summarises the feedback received to such consultation as well as the Regulators’ response. Changes confirmed in the Policy Statement include:

• the addition of a new Field 30 (Execution agent) in the reporting technical standards; and
• the correction of a cross-referencing error relating to Unique Transaction Identifiers.

The Policy Statement will primarily affect counterparties subject to UK EMIR reporting, UK EMIR registered or recognised TRs, and third-party service providers involved in UK EMIR reporting. 

In response to consultation feedback, the implementation date of the final rules has been changed to 26 January 2026. Alongside the Policy Statement, the BoE has published final validation rules and updated XML reporting schemas, which will apply from the same date. 

The Consultation, Policy Statement, validation rules, XML reporting schemas: Incoming messages to TRs and Outgoing messages from TRs are available here, here, here, here and here, respectively.