Under Article 9 of UK European Markets Infrastructure Regulation (UK EMIR), all counterparties must report any derivative contract concluded, modified or terminated.
Changes to the derivatives reporting framework under UK EMIR – supporting documentation
On 24 February 2023, we published a joint FCA/Bank of England Policy Statement (PS 23/2) alongside the supporting documentation below (collectively referred to as the ‘new requirements’).
The amended Technical Standards that relate to the registration of TRs and miscellaneous amendments came into force on 24 February 2023.
On 30 September 2024, further changes came into effect:
- EMIR Technical Standards on the Minimum Details of the Data to be Reported to Trade Repositories 2023
- EMIR Technical Standards on the Standards, Formats, Frequency and Methods and Arrangements for Reporting 2023
- The European Market Infrastructure Regulation Rules (FCA EMIRR) for Trade Repositories.
In August 2025, we published Handbook Notice No 132 alongside final Technical Standards to make minor amendments to the UK EMIR requirements.
The amended Technical Standards, final UK EMIR Validation Rules and XML schemas all entered into force on 26 January 2026.
On 16 April 2026, we published an update to the UK EMIR Validation Rules, to reflect changes to the reconciliation requirements.
Below are the latest UK EMIR Validation Rules and XML schemas.
- UK EMIR Validation rules
- XML Schemas under UK EMIR
UK EMIR REFIT transition period
From 30 September 2024 all newly entered or modified derivative trades at both trade and position level need to comply with the new requirements.
For derivative trades entered into before 30 September 2024, there was a 6-month transition period for entities responsible for reporting to update those outstanding derivative reports to the new requirements. This ended on 31 March 2025.
UK EMIR reporting questions and answers
We have produced guidance in the form of questions and answers (Q&As) for the new UK EMIR reporting requirements.
UK EMIR errors and omissions notification form
UK EMIR errors and omissions notification form
You should use this form to notify us of any errors or omissions you deem to be material in your reports under Article 9 of UK EMIR.
The entity responsible for reporting is required to notify the FCA as soon as it becomes aware of material errors or omissions in reporting in compliance with Article 10 of EMIR Technical Standards on the Standards, Formats, Frequency and Methods and Arrangements for Reporting 2023.
If any details are unknown at the point of submitting the Errors and Omission notification, an update should be provided once these details are known, with reference to the original notification.
Requirements for reporting to TRs
All new derivative trades entered into by UK counterparties, on or after 11pm on 31 December 2020, are in scope of the UK EMIR reporting regime and must be reported to an FCA registered or recognised TR.
It is possible to meet the reporting obligation by reporting to any FCA registered or recognised TR.
The details to be reported are set out in the EMIR Technical Standards on the Minimum Details of the Data to be Reported to Trade Repositories 2023.
TRs registered or recognised by us
UK EMIR trade reports may only be submitted to trade repositories which are registered or recognised by us.
Four TRs have been registered by us and will offer services to UK clients from the end of the EU withdrawal transition period:
- ICE Trade Vault Europe Limited
- LSEG Regulatory Reporting Limited
- DTCC Derivatives Repository Plc
- REGIS-TR UK Limited
More information on FCA registered, or recognised, TRs can be found on the TR webpage.
How to fulfil the reporting obligation
Both counterparties must report their side of the trade unless, by prior arrangement, one party can report on behalf of both counterparties (or the law requires a financial counterparty to report on behalf of its counterparty – as to which see the further point below). Where one report is made on behalf of both counterparties, the report must indicate this fact. The UK EMIR Technical Standards set out what information shall be submitted in relation to each of the counterparties, and what information shall be submitted only once.
- Either counterparty to the trade may delegate reporting to a third party (such as a central counterparty or trading platform).
- Where one counterparty reports on behalf of another counterparty, or a third party reports a contract on behalf of one or both counterparties, the details reported shall include the full set of details that would have been reported had the contracts been reported by each counterparty separately.
- A financial counterparty is solely responsible and legally liable for reporting on behalf of both counterparties, the details of OTC derivative contracts concluded with a non-financial counterparty not subject to the clearing obligation. To make sure the financial counterparty has the data it needs to fulfil its reporting obligation, the non-financial counterparty must provide the financial counterparty the details relating to the OTC derivative contracts concluded between them, which the financial counterparty cannot be reasonably expected to possess. If the non-financial counterparty wishes to continue to report these OTC derivative contracts, they may do so, but they should inform the financial counterparty accordingly.
- If one or each of the counterparties in an OTC derivative is a UCITS or an AIF (including third country AIF), the management company of the UCITS or the AIF manager (as applicable) is responsible for the reporting on behalf of that UCITS or AIF.
- The authorised entity responsible for managing and acting on behalf of an IORP that does not have legal personality will also be responsible for reporting the details of OTC derivative contracts on behalf of that IORP.
- If a non-financial counterparty is not subject to the clearing obligation and concludes an OTC derivative contract with an entity established in a third country, that OTC derivative contract does not need to be reported by the non-financial counterparty, provided that:
- The third-country entity would be qualified as a financial counterparty if it were established in the UK.
- The legal regime for reporting to which the third-country entity is subject is declared equivalent under Article 13 of UK EMIR.
- The third-country entity has reported the details of the OTC derivative contract pursuant to that third-country legal regime for reporting to a TR, which is legally bound to provide access to the data to the entities referred to in Article 81(3) of UK EMIR.
Intragroup reporting exemption
Derivative contracts within the same group where at least one counterparty is a non-financial counterparty (or would be qualified as a non-financial counterparty if it were established in the UK) are exempt from the reporting obligation provided that specific conditions are met.
If you intend to take advantage of this exemption, you must first notify us.
Please see our EMIR notifications and exemptions webpage for more information on how to notify us.
Issuance of legal entity identifiers
All UK counterparties entering into derivative trades need to have a Legal Entity Identifier (LEI) in order to meet the UK EMIR reporting obligations.
LEIs are issued by Local Operating Units (LOUs) on the Global LEI System.
The list of LOUs accredited by the Global LEI Foundation (GLEIF) can be found on the GLEIF website and includes the London Stock Exchange. Some of these registries serve a given country, while others offer services to entities worldwide.
LEIs issued by pre-LOUs that have been endorsed by the ROC or accredited by the Global LEI Foundation can also be used for UK EMIR reporting.
More information on how to obtain an LEI can be found on the LEI ROC website.
Note on EU withdrawal transition period
On 24 November 2020 we published a Note on UK EMIR reporting requirements.
This note explains what Trade Repositories (TRs), and UK counterparties that use them, should do to make sure they are compliant with their UK EMIR reporting obligations following the end of the transition period agreed under the Withdrawal Agreement between the EU and the UK.
A list of UK EMIR onshoring legislation can be found on the UK EMIR library page.
