On 24th February 2023, the FCA issued an update regarding changes to the UK EMIR derivatives reporting framework. The joint FCA/Bank of England Policy Statement (PS 23/2) announced that the new rules will come into force from 30 September 2024, as well as publishing draft versions of EMIR Validation Rules and Incoming/Outgoing XML schema. Firms can submit feedback for technical specification documents until the 24th of March 2024, with the final versions expected to be released shortly after this date.
Although the UK rewrite remains largely in line with ESMA, there are some differences to be aware of:
- Dual Reporting Obligations Dates: With the ESMA deadline date on 29th April 2024, separate to the FCA 30 September 2024 date, firms with dual reporting obligations will need to provide two versions of EMIR reporting.
- Delegated Reporting: Regarding cross-jurisdiction reporting, EU entities currently providing delegated reporting to customers in the UK will continue to provide this in the existing format for clients but will need to use the updated Refit version internally. There is also additional pressure on UK firms providing delegation to EU firms, as they will need to be compliant by the earlier ESMA date of 29th April 2024 rather than the September deadline.
- Field and Validation Discrepancies: ‘Execution Agent’ is an additional field allowing third parties to be tagged by firms on their behalf. Various validations have been amended in the XML Schema Definitions (XSD) as well as a number of additional slight changes by the FCA.
As the EU and UK frameworks continue to be updated in the future, it may become more difficult for firms to manage these discrepancies and requirements. Get in touch today to find out how we can assist your firm with the upcoming changes.
How MAP FinTech may assist
MAP FinTech is a leading award-winning global regulatory technology provider, highly regarded for its proprietary reporting technology and exceptional client-centric after-sales support. As one of the first providers in Europe to report under the European Market Infrastructure Regulation (EMIR), with billions of transactions reported successfully so far, we have built a reputation for excellence, coupled with the necessary regulatory expertise and technological innovation to assist firms in navigating their respective regulatory obligations. Contact our team of experts to find out how you can benefit from our innovative and comprehensive regulatory reporting solutions.