On 6th June 2025, the Financial Conduct Authority (FCA) and the Bank of England published a joint consultation (CP25/16: Quarterly Consultation Paper No. 48) proposing minor but important updates to the UK European Market Infrastructure Regulation (UK EMIR) reporting framework.
What’s Changing?
As part of ongoing efforts to streamline and enhance the UK EMIR reporting regime, the Authorities are proposing the following amendments:
1. New Field: Execution Agent
A key proposal is the addition of a new data field — “Execution Agent” — to Table 3 (Collateral table) of the Annexes within both:
The EMIR Technical Standards on the Minimum Details of the Data to be Reported to Trade Repositories 2023, and
The EMIR Technical Standards on the Standards, Formats, Frequency and Methods and Arrangements for Reporting 2023.
This addition is designed to enhance the clarity and completeness of reported transaction data. Consequential cross-referencing updates will be made throughout the Technical Standards to support this change.
Note that the Execution Agent field only applies to UK EMIR and does not exist within EU EMIR reporting requirements.
2. Schema and Validation Rule Updates
Corresponding amendments are being proposed to the Schemas and Validation Rules, not just for the Execution Agent field but also for several other fields, improving the consistency and functionality of the reporting system.
3. Correction to Article 8(5): Unique Transaction Identifier (UTI)
The consultation also addresses a cross-referencing error in Article 8(5) relating to the UTI, correcting it within the 2023 Reporting Standards.
Key Dates and Next Steps
Market participants should be aware of the following timeline:
Consultation Period: Open until 30th June 2025. Firms are encouraged to review the proposals and provide feedback to the FCA via the CP25/16 online response form.
Final Technical Standards: Expected to be published by 1st August 2025.
Proposed Effective Date: The new reporting requirement is planned to take effect on 1st December 2025.
What Firms Should Do
Firms subject to UK EMIR reporting should begin preparing for this change now:
Review current reporting systems to assess readiness for XML schema updates.
Engage with vendors and trade repositories to ensure timely adoption.
Participate in the consultation process if this change will materially impact operations.
Useful Links
This is yet another example of the UK regulatory landscape continuing to evolve post-Brexit, with a growing divergence from EU rules. Staying informed and adaptable is critical.
For any further queries, stakeholders are encouraged to reach out via the dedicated mailbox: EMIRreporting@fca.org.uk.