As the financial industry continues to evolve, regulatory compliance remains a cornerstone of operational integrity and market confidence. The Financial Conduct Authority’s (FCA) UK EMIR Regulatory Fitness Program (UK EMIR REFIT), which impacts regulatory reporting changes, came into effect on September 30, 2024 and represents a significant milestone in this journey. With the transition period concluding on March 31, 2025, firms must act swiftly to align with the new standards and avoid potential compliance pitfalls.
The UK EMIR REFIT aims to enhance transparency in derivatives transactions and harmonize regulatory reporting across jurisdictions. This initiative has introduced several key changes, including an increase in the number of reportable fields from 129 to 200 and the requirement to standardize reporting via XML in ISO 20022 format. These changes are designed to improve data quality and ensure that all market participants adhere to a consistent reporting framework.
One of the most critical aspects of the UK EMIR REFIT is the mandate that all outstanding trades and associated collateral margins reported before September 30, 2024, and do not mature or early terminate during the transition period, must be updated to meet the new reporting standards. This requirement has necessitated significant system enhancements for entities responsible for reporting to enrich legacy trades with the newly required data points. The FCA has provided a six-month transition period to facilitate this, the clock is ticking.
From our vantage point as the largest FCA-regulated trade repository for UK EMIR, the early results of the REFIT are promising. Since its implementation, we have observed a steady improvement in data quality, with the acceptance rates for new submissions at an average of approximately 98%. Although most firms are making good progress, approximately 5% of legacy trades are still to be upgraded.
At DTCC, we are committed to supporting our clients through this transition and beyond. Our best-in-class client support teams, deep subject matter expertise, comprehensive reporting behavior and data quality insight tools and DTCC Consulting Services – which has a focus on regulatory reporting – uniquely position us to help firms navigate the complexities of the UK EMIR REFIT and other global rewrites. Our Global Trade Repository (GTR) service recently won Trade Repository of the Year 2025 at the FOW International Awards in London, which stands as a testament to our dedication to excellence.
As the March 31, 2025 deadline approaches, it is imperative for firms to ensure that their reporting systems are fully aligned with the UK EMIR REFIT standards. Failure to do so will result in non-compliance and increased scrutiny from the FCA. Based on what we have seen previously, we anticipate the FCA will take a dim view of compliance failures. By leveraging the resources and expertise available, firms can not only meet regulatory requirements but also enhance their operational resilience and market competitiveness.
For further information and support, clients are encouraged to access relevant resources on the DTCC Learning Center or visit the DTCC Client Center.