As part of the European Market Infrastructure Regulation (EMIR) Refit, the FCA and Bank of England have proposed changes to EMIR Article 9 reporting. Although these changes are minor, even small tweaks can have big implications if your transaction reporting processes are not watertight.
What’s Changing?
Article 9 of the UK EMIR framework requires counterparties to derivatives contracts to report detailed information about trades to a registered trade repository. This reporting helps regulators monitor systemic risk and detect potential market abuse.
The regulators are consulting on two technical amendments to this article, aligning with broader transparency reforms in bond and derivatives markets. Feedback on these amendments is due by 30 June 2025, with an expected go-live date of 1 December 2025.
Here’s what’s proposed:
- New Field: Execution Agent: A new field (Field 30) will be added to the Margin Requirements (Table 3), mirroring the existing Execution Agent field in Table 1 (Field 21).
- Technical Corrections: Minor cross-referencing errors in Article 8(5) of the Technical Standards in relation to Unique Transaction Identifier will be corrected.
- Feedback on Timing: Stakeholders are invited to comment on the proposed effective date.
These proposals follow the more substantial reforms introduced in Policy Statement PS23/2, which took effect 30 September 2024 in the UK. Those changes included:
- New XML schemas and validation rules for trade reporting
- Revised technical standards on data fields, formats, and reporting frequency
- Stricter expectations around data quality and completeness
Why This Matters
These changes come amid a broader regulatory push for greater transparency and accountability in trade and transaction reporting. In recent months:
- A UK-based trading firm was fined £99,200 for failing to report over 46,000 transactions under Markets in Financial Instruments Regulation (MiFIR).
- Another firm was penalized £9.2 million for breaches related to market conduct and reporting obligations.
- Updated Q&A guidance and validation rules for EMIR reporting took effect from 30 September 2024, with new XML schemas and stricter expectations around data quality.
- ESMA have called for evidence with a view to simplifying and streamlining reporting regimes (MiFIR, EMIR, and SFTR).
- A speech from the FCA’s CEO in June 2025 highlighted the ongoing importance of quality data to enable the regulator to safeguard market integrity and confidence.
These actions highlight a clear trend: regulators are focused on the quality of reporting, no longer tolerating poor reporting practices, and enforcement is becoming more frequent and costly.
Working with a specialist partner, like ACA, can help firms navigate these changes confidently, ensuring reporting frameworks are resilient, accurate, and audit-ready.
Take the Next Step
At ACA, we understand the complexity and constant evolution of regulatory reporting. That’s why we developed ARRMA, ACA’s Regulatory Reporting Monitoring and Assurance solution.
With ARRMA, you get:
- End-to-end oversight of your EMIR and MiFIR reporting obligations
- Automated reconciliations to identify gaps and inconsistencies
- Real-time exception management and alerts
- Audit-ready reporting with full traceability
- Specialist support to interpret and implement regulatory changes
Book a free ARRMA review to discover how ARRMA can help you reduce operational risk, improve data quality, and stay compliant—no matter how often the rules change.