UK EMIR reporting update August 2025

1. Updates to UK EMIR reporting technical standards, validation rules and XML schemas - effective 26 January 2026

In June 2025, the Financial Conduct Authority (FCA) and the Bank of England (the Bank, and together with the FCA the Authorities) consulted on two proposed amendments to their respective UK EMIR reporting technical standards.

The first amendment addresses an oversight that had resulted in the (optional) 'Execution agent' field being included in the trade reporting requirements but omitted from the margin reporting requirements. The second amendment updates cross-references in Article 8 (Unique Transaction Identifier) of the technical standards.

The Authorities have decided to implement both proposals and, in August 2025, published their updated technical standards (FCA Handbook Notice 132, Bank of England Policy Statement). They will come into force on 26 January 2026. Updated validation rules and XML schemas have also been published and will apply from the same date.

2. Consultation on two new UK EMIR reporting Q&As - open until 12 September 2025

On 8 August 2025, the FCA and the Bank opened their third consultation on Q&As for UK EMIR reporting. They are seeking feedback on two new draft Q&As addressing the following questions:

• When is it acceptable to report with a technical ISIN?

• How should an 'FX swap' be reported?

The consultation is open until 12 September 2025.

If you would like to discuss any aspect of this with us, please do get in touch.