FCA Market Watch 84

FCA Market Watch 84

2025-09-30

In this edition , the FCA and Bank of England reviewed the UK EMIR reporting regime following the REFIT changes introduced in September 2024. These changes aim to:

  1. Improve transparency in derivatives reporting
  2. Enhance data quality for trade repositories
  3. Align with international standards to strengthen global consistency

Why this matters
High-quality EMIR data is critical and is used by the FCA and the Bank of England for monitoring systemic and financial stability risks. It has been central in areas such as:

  • Tracking the use of benchmarks in commodities and rates markets
  • Informing policy and firm outreach
  • Providing clarity during periods of market volatility (e.g. April’s tariff announcements)

Current challenges
Despite strong compliance rates, issues remain:

  • 4.81% of trades were not updated before the transition deadline (March 2025)
  • 19% of counterparties faced reporting challenges
  • 1.45% failed to report trades entirely

The FCA highlighted two main drivers:

  1. Inadequate resource planning – Firms must allocate sufficient resources and clear policies to meet compliance deadlines.
  2. Over-reliance on external vendors – Counterparties remain responsible for the accuracy and completeness of reporting, even when outsourcing.

Looking ahead
Over the next 12 months, the FCA will:

  • Focus on reconciliation rates
  • Closely monitor breach notifications
  • Engage with firms to improve systems, controls, and reporting accuracy

At P9, we’re proud to have successfully implemented UK EMIR REFIT and continue to support our clients in meeting their reporting obligations with accuracy and confidence. By delivering high-quality data, we enable regulators to safeguard financial stability while giving firms peace of mind that they remain compliant. Get in touch with us today to see how we can support your reporting needs.

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