Are you EMIR-ready? Key changes coming in December

July 22, 2025

As part of the UK’s ongoing efforts to enhance financial market transparency, the Financial Conduct Authority (FCA) and the Bank of England have issued a consultation on proposed changes to EMIR Article 9 reporting.

According to ACA Group, these updates, though technical and relatively minor in scope, have significant implications for firms handling derivatives transactions, particularly those lacking robust reporting frameworks.

Under the European Market Infrastructure Regulation (EMIR) Article 9, counterparties to derivatives contracts are required to report transaction details to a registered trade repository. This mechanism enables regulators to assess systemic risk and monitor for potential market abuse. The new proposals focus on two core amendments, which align with broader reforms to improve transparency across bonds and derivatives markets. Stakeholder feedback is due by 30 June 2025, with implementation expected by 1 December 2025.

The proposed changes include the introduction of a new data field—Field 30: Execution Agent—to Table 3 (Margin Requirements), bringing it in line with an existing field in Table 1. Additionally, the FCA and Bank of England intend to correct several cross-referencing errors related to the Unique Transaction Identifier under Article 8(5) of the Technical Standards. Industry participants are also invited to share views on the proposed timeline for implementation.

These technical refinements build upon the UK’s broader EMIR Refit reforms introduced under Policy Statement PS23/2, which came into force on 30 September 2024. Those reforms featured a complete overhaul of the technical standards, including revised XML schemas, updated validation rules, and stricter expectations around data quality, frequency, and completeness of transaction reporting.

The need for high-quality data is increasingly being underscored by regulators. Recent enforcement actions demonstrate the rising cost of non-compliance. One UK-based trading firm was fined £99,200 for failing to report over 46,000 transactions under MiFIR. Another received a £9.2m penalty for broader failures in market conduct and transaction reporting. Updated EMIR Q&A guidance and validation rules also took effect from 30 September 2024, further raising the bar for compliance.

These developments are part of a larger regulatory trend. The European Securities and Markets Authority (ESMA) recently called for evidence aimed at simplifying and streamlining reporting under EMIR, MiFIR, and SFTR. In June 2025, the FCA’s CEO delivered a speech reinforcing the message that high-quality, reliable data is fundamental to protecting market integrity and maintaining public confidence.

For firms looking to keep pace, working with a specialist compliance partner such as ACA can help ensure readiness. These experts offer guidance on building resilient reporting frameworks that meet evolving regulatory standards, minimising compliance risk and preparing for scrutiny.