UK EMIR re-reporting deadline is imminent
Entities responsible for reporting have until the end of the transitional period (31 March 2025) to update outstanding derivative reports in line with new rules
The UK EMIR derivatives reporting regime underwent a wholesale change on 30 September 2024, with the introduction of more reporting fields, more specificity and standardisation, a specific misreporting notification obligation (with a materiality threshold), and more guidance (read more in our previous article).
We are now less than a month away from the related 're-reporting' deadline. Entities responsible for reporting are to ensure any outstanding derivative reports are updated in line with the new rules by the end of the transitional period on 31 March 2025.
Those subject to UK EMIR reporting should be checking on the progress of this exercise and assessing whether they are on track to meet the deadline. Where voluntary delegation arrangements, e.g., to broker counterparties, are in place, remember that the regulatory responsibility and liability nonetheless remains with the entity responsible for reporting for UK EMIR purposes.
As a reminder, even third-country (e.g. Cayman) AIFs are in scope of UK EMIR, including the re-reporting obligation, where they have a UK AIFM.
Note also the Financial Conduct Authority's expectation that entities responsible for reporting proactively engage with it ahead of the completion of the transition period, with explanation, if they are at risk of not updating their outstanding reports to comply with the new requirements after 31 March 2025 (UK EMIR reporting Q&A 1.1).
If you would like to discuss any aspect of this with us, please get in touch.
