EMIR Refit in practice: lessons from a year of dual reporting

Inside the Refit: what changed across the EU and UK regimes

The EU EMIR Refit went live on 29th April 2024, while the UK EMIR Refit went live the following 30th September. Both frameworks were designed to improve the quality, consistency, and usability of derivatives data. While the core objectives were aligned, the implementation varied, with staggered timelines and jurisdiction-specific nuances.

Common reforms included:

• Submissions now use the ISO 20022 XML format
• Number of reportable fields significantly increased
• Unique Product Identifier (UPI) now mandatory for standardised OTC products
• Action and event types expanded
• Greater emphasis on LEIs and accurate counterparty data and classification

One year on: how the market is adapting

EU Refit impact: data quality improvements and ongoing challenges

In its recent data quality report, the European Securities and Markets Authority (ESMA) noted a material improvement in reporting consistency and reconciliation rates compared to pre-Refit figures. Many of these gains were attributed to the stricter validations now applied across all EU Trade Repositories.  However, challenges remain:

• Frequent rejection of lifecycle events due to mismatched UTIs or timestamps
• Misuse of action types like “Update” and “Modify”
• Limited UPI availability for less liquid OTC products

UK: late start, similar challenges

Firms had a shorter runway to adapt to UK-specific tweaks, and while many leveraged EU implementation lessons, the UK EMIR Refit hasn’t been without issues:

• The Financial Conduct Authority (FCA)’s 31 March 2025 backloading deadline has triggered a wave of legacy trade corrections
• Divergences in validation logic between UK and EU repositories caused mismatches
• Uncertainty around action/event type mapping under the UK regime prompted industry Q&As

Dual reporting: a complex reconciliation landscape?

While both regimes are broadly aligned, firms reporting to both the EU and UK face unique operational burdens:

• Same trade but different schemas, validations and timelines
• Need for dual UTI coordination and sequencing
• Data fragmentation between EU/UK trade repositories

Globally active firms have had to invest in regime-specific workflows, transformation layers, and cross-regional governance – a challenge, but also an opportunity to future-proof their reporting architecture.

Through the regulators’ lens: key findings and focus areas

Supervisory efforts in both jurisdictions are shifting from education to enforcement.  Recent audits by regulators have flagged:

• Incorrect action/event usage
• Incomplete reporting of post-trade events (e.g. compressions, novations)
• Gaps in UPI/UTI population and counterparty LEI matching

Firms are expected to justify their reporting logic, show robust internal controls, and demonstrate evidence of reconciliation and remediation processes. Regulatory scrutiny is only set to intensify, and firms must treat reporting compliance as a continuous process, not just a one-off project.

Lessons from the front lines of Refit reporting

1. ISO 20022 is not just a format change. It demands deeper operational alignment between front, middle, and back office.
2. Start testing early. Both pre- and post-go-live dry runs were invaluable for firms that hit the ground smoothly.
3. Vendor responsiveness proved critical. The flexibility of third-party platforms often determined the success of go-lives.
4. Counterparty collaboration matters. Many breaks were traced to simple misalignments between counterparties.

What’s next on the EMIR Refit journey?

With EU Refit now operational for a full year and the UK 6 months behind, attention turns to:

• Ongoing reconciliation and remediation: expect ongoing work to clear legacy breaks and reconcile trade repositories. EU firms must also be ready for more intrusive supervisory reviews in 2025
• UK backloading milestone: 31st March 2025 will see the end of the backloading grace period in the UK.  All legacy trades should now be converted to the new format and fully compliant with UK EMIR Refit rules.
• Push for global harmonisation: regulators globally are watching. The Committee on Payments and Market Infrastructures (CPMI)-International Organization of Securities Commissions (IOSCO) UPI mandate (effective since January 2024) is already feeding into cross-border reporting expectations
• Towards an ESMA-FCA alignment? While formal alignment between ESMA and the FCA remains unlikely in the near term, industry momentum is building for clearer guidance and cross-regime consistency.

Final thoughts

One year in, the EMIR Refit transformation is still unfolding, but for many firms, the steepest part of the curve is behind them. Data quality is improving, reporting maturity is growing, and the long-term benefits of transparency are beginning to show.

In a dual-regime world, firms that invest in scalable, adaptive reporting infrastructures will be best positioned to meet evolving regulatory expectations.