FCA Publishes Market Watch Issue 84 on UK EMIR Refit Implementation

On 30 September 2025, the Financial Conduct Authority (FCA) published issue 84 of Market Watch (Issue 84), providing a one-year review of the UK European Market Infrastructure Regulation (UK EMIR) Refit implementation and its impact on derivatives reporting, data quality and compliance across the UK market. 

Market Watch is the FCA’s regular newsletter on market conduct and transaction reporting matters. 

Background

On 30 September 2024, the FCA and the Bank of England (BoE) introduced changes to the UK EMIR reporting regime, known as UK EMIR Refit. The reforms aimed to enhance transparency in derivatives reporting, improve data quality submitted to trade repositories and align the UK’s framework with international standards. 

UK EMIR Implementation

Following the implementation of UK EMIR Refit, reporting counterparties were required to report new derivative contracts in accordance with the new requirements. There was also a six-month transition period for uplifting outstanding derivative trades entered into before 30 September 2024, which ended on 31 March 2025.

Issue 84 explains that, by the end of the transition period, 95% of reports had been successfully uplifted. The FCA acknowledges the significant efforts made by counterparties to meet these deadlines. However, Issue 84 notes that a small number of counterparties maintained non-uplifted reportable trades beyond 31 March 2025, resulting in breaches of reporting obligations. 

Issue 84 reiterates that the FCA expects all counterparties to uplift eligible trades as soon as possible to restore compliance with their reporting obligations.

Change Management 

Despite over 18 months’ notice, Issue 84 states that 4.81% of trades were not uplifted before the end of the transition period. 

In Issue 84, the FCA also identifies that 19% of counterparties experienced challenges with reporting following UK EMIR Refit implementation, and 1.45% of UK reporting counterparties failed to report derivative trades entirely under the new regime. The FCA state that these shortcomings have materially affected the FCA’s visibility of the UK derivatives market, and its ability to monitor systemic risk and obtain data insights.

Issue 84 sets out two main factors contributing to counterparties’ UK EMIR Refit implementation challenges:

• Inadequate resource planning. Some counterparties did not allocate sufficient resources to change management activities or encountered key person dependencies, leading to delays and unresolved issues.
• Increased reliance on external vendors. While third-party vendor use has increased significantly (with some vendors doubling their daily reporting volumes post-UK EMIR Refit), deficiencies in vendors’ data mapping, enrichment and schema logic have resulted in poor-quality reports.

The FCA emphasises that responsibility for complete and accurate reporting remains with the counterparty, regardless of vendor involvement. Material issues with reported data caused by vendors must be notified to the FCA via breach notifications.

Errors and Omissions Management

Since UK EMIR Refit went live on 30 September 2024, the FCA has received breach notifications for 267 distinct reporting issues –­­­­­­­­­ a figure it considers lower than expected. The FCA notes that counterparties may have differing thresholds for what constitutes a material breach but expects comprehensive and timely notifications of any material errors or omissions.

Central counterparty clearing houses should notify the BoE, while other counterparties should notify the FCA using the prescribed form. If a counterparty is uncertain about the materiality of an error, it should notify the FCA.

Next Steps

Issue 84 sets out the FCA’s priorities for the next 12 months to improve overall data quality, including:

• supporting industry efforts to improve the accuracy and completeness of reporting;
• increasing its focus on reconciliation rates;
• closely monitoring breach notifications and engaging with firms that do not meet expectations; and
• assessing counterparties’ systems and controls to ensure accurate reporting and timely correction of errors.

The FCA explains that counterparties should review their arrangements in light of these priorities and consult the FCA’s reporting obligation webpage for further guidance. 

Key Takeaways 

Firms with reporting obligations under Article 9 of UK EMIR should consider how Issue 84 aligns with their existing processes and reporting frameworks. Such firms should also consider the Reporting Q&As published by the FCA and BoE.

Issue 84 highlights the FCA’s commitment to improving the quality of derivatives reporting under UK EMIR. The publication reminds firms of their ongoing obligations and the importance of effective change management and vendor oversight in meeting regulatory requirements. 

Issue 84 and the Reporting Q&As are available here and here, respectively.