UK regulators are stepping up efforts to refine derivatives reporting requirements under the European Market Infrastructure Regulation (EMIR) Refit. The Financial Conduct Authority (FCA) and the Bank of England are proposing targeted updates to Article 9 reporting rules, aiming to bring greater transparency and accuracy to trade data reporting.
According to ACA Group, at the heart of the proposal are two amendments: the addition of a new field—Execution Agent—to Margin Requirements in Table 3 (Field 30), mirroring a similar field in Table 1, and the correction of technical cross-referencing errors related to the Unique Transaction Identifier under Article 8(5). Stakeholders have until 30 June 2025 to submit feedback, and if approved, the changes will take effect on 1 December 2025.
These amendments build on more substantial reforms implemented in the UK last year through Policy Statement PS23/2, which came into force on 30 September 2024. That package of reforms introduced revised XML schemas, stricter validation rules, and new data quality standards, raising the bar for firms’ transaction reporting systems.
While the latest changes are modest in scale, the broader regulatory trend is clear: firms are under increasing pressure to ensure their reporting is complete, accurate, and timely. Regulatory bodies in the UK and Europe have intensified scrutiny of transaction reporting under EMIR, MiFIR, and SFTR.
Recent enforcement actions underline the risks of falling short. One UK-based trading firm was fined £99,200 for failing to report more than 46,000 transactions under MiFIR. Another was hit with a £9.2m penalty for breaches tied to market conduct and reporting obligations. These cases send a strong message: incomplete or faulty reporting is no longer tolerated.
Further reinforcing this shift, the European Securities and Markets Authority (ESMA) recently launched a call for evidence on harmonising and simplifying reporting frameworks. Additionally, updated FCA Q&A guidance and new validation rules took effect from September 2024, with a continued emphasis on XML format compliance and data integrity.
The FCA’s CEO also addressed these themes in a speech in June 2025, stressing the need for “robust, high-quality data” to ensure market integrity. Firms must now go beyond tick-box compliance and embrace a more proactive, data-first approach to regulatory reporting.
Partnering with a compliance specialist such as ACA can help financial institutions futureproof their operations. With expert guidance, firms can develop resilient, audit-ready reporting frameworks that meet the evolving expectations of regulators.
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