Trade reconciliation under EMIR is entering a significantly more stringent phase. From 27 April 2026, trade repositories will apply an expanded and more detailed reconciliation framework, increasing both the number of fields compared and the complexity of the matching logic. These changes are designed to strengthen data quality, improve supervisory outcomes, and align reconciliation practices more closely with the ESMA EMIR REFIT framework.
Point Nine (P9) is closely reviewing these upcoming changes and their operational impact. As part of our readiness programme, we will begin UAT testing from February 2026, allowing clients ample time to assess the effects, validate reporting behaviour, and prepare for go-live.
A More Structured and Granular Reconciliation Process
The updated reconciliation framework continues to operate on a D+2 business-day cycle, aligned with the TARGET2 calendar. However, it introduces clearer separation and expansion of reconciliation stages:
- Transaction pairing, based on UTI consistency and cross-matching of counterparty LEIs
- Data comparison (matching), applied only once transactions are successfully paired
- Valuation reconciliation, with enhanced tolerances and explicit exclusion rules
Only the latest transaction state at end-of-day is reconciled, meaning intraday amendments are ignored for reconciliation purposes. This “last state” rule increases the importance of accurate lifecycle management and timely corrections.
Phase II: A Major Expansion of Reconciled Fields
One of the most significant changes is the implementation of Phase II reconciliation, which materially expands the number of fields subject to comparison. From April 2026, reconciliation will no longer focus only on a core subset of fields but will cover a much broader range of data, including:
- Additional contract identifiers and links (e.g. prior and subsequent UTIs)
- Extended product and underlying details, including baskets and crypto-asset indicators
- Detailed transaction economics such as prices, notionals, spreads, other payments, and package transactions
- Asset-class-specific fields across interest rates, FX, commodities, options, and credit derivatives
In many cases, no tolerance is allowed, meaning values must match exactly between counterparties. Where tolerances do apply, these are precisely defined (for example, rounding rules or percentage-based thresholds), and are applied consistently across trade repositories.
Importantly, every reconciliation run compares the full set of applicable fields, even when only a valuation update has been submitted. This increases the likelihood that legacy or static data issues will surface during daily reconciliation.
Enhanced Valuation Reconciliation
Valuation reconciliation has also been formalised and tightened. Financial counterparties, NFC+s, and CCPs must ensure that end-of-day valuations are not only reported but also aligned within prescribed tolerances.
Key enhancements include:
- Explicit differentiation between mark-to-market, mark-to-model, and CCP valuations
- Percentage-based tolerance thresholds for MTM and MTM/MTMO comparisons
- Mandatory opposite signs for valuations reported by counterparties
- Clear rules on when valuation reconciliation is not applicable, for example for NFC- trades or certain ETDs
Valuation reconciliation results are reported separately from non-valuation reconciliation, meaning a trade can be fully reconciled on core fields but still fail valuation reconciliation.
More Detailed Reconciliation Reporting
Reconciliation results will continue to be delivered via immediate intraday reports and end-of-day aggregate reports, but with significantly richer content. As the number of reconciled fields increases, reports will include more detailed mismatch information, making discrepancies easier to identify but also more numerous if upstream data is inconsistent.
This reinforces the need for firms to have robust reconciliation monitoring, break analysis, and remediation workflows in place.
Point Nine Readiness and Client Testing
Point Nine is actively analysing the new reconciliation framework and incorporating the requirements into our reporting, reconciliation, and monitoring processes. Given the scale of the changes, we strongly believe that early testing is essential.
- UAT testing will commence from February 2026
- Clients will be able to validate reconciliation behaviour ahead of the April 2026 effective date
- Testing will focus on expanded field coverage, tolerance handling, lifecycle scenarios, and valuation reconciliation outcomes
As always, P9’s objective is to shield clients from unnecessary complexity while ensuring full regulatory compliance.
What Clients Should Do Next
Firms should begin assessing their EMIR reporting data with reconciliation in mind not just validation. Particular attention should be paid to static data alignment between counterparties, lifecycle event consistency, valuation methodologies, and rounding conventions.
Point Nine will continue to provide updates as testing progresses and will work closely with clients to ensure a smooth transition to the enhanced reconciliation regime.
