Changes to UK EMIR reporting requirements: draft questions and answers

Why we consulted

On 24 February 2023, we published a joint Policy Statement (PS23/2[1]) with the Bank confirming changes to the derivative reporting framework under UK EMIR[2]. The majority of the new requirements are applicable from 30 September 2024, with a transition period for some aspects.

As part of the original consultation process, we received requests for supporting guidance on how the updated UK derivatives reporting framework will be implemented.

In response, we've provided guidance to support the implementation of the updated UK EMIR reporting requirements that apply from 30 September 2024. This guidance is in the form of questions and answers (Q&As) grouped into topics. Before finalising these Q&As, we consulted on them jointly with the Bank to get feedback from industry.

Draft Q&As

The Q&As we consulted on were informed by discussions with trade associations, reporting counterparties, TRs and central counterparties (CCPs) via the UK EMIR Reporting Industry Engagement Group. The group, co-chaired by us and the Bank, provides a forum for discussing derivatives reporting issues with industry to help ensure consistent reporting.

The Q&As were divided up into the following topics. We've consulted on topics 1 to 5, and those Q&As are now finalised[3]. In the second consultation, we covered topics 6 to 11, alongside some additional Q&As under topics 1, 4 and 5. Those Q&As are also now finalised.

1. Transitional arrangements  
2. Reconciliations 
3. Errors and omissions 
4. Derivative identifiers 
5. Action and Events 
6. Venues 
7. Exchange traded derivatives 
8. Margin and collateral 
9. Clearing 
10. Position level reporting 
11. Asset class and product specific  

UK EMIR Validation Rules (applicable from 30 September 2024)

In certain circumstances, the Q&As required corresponding changes to the UK EMIR Validation Rules (applicable from 30 September 2024)[4]. As a result, we also consulted on those changes on an exceptional basis and invited participants to provide feedback.

The UK EMIR Validation Rules (applicable from 30 September 2024) have now been finalised and we don’t intend to make further changes before 30 September 2024. The finalised changes have been marked in red within the document for visibility. We've also implemented a minor change to the schema to address an error with field 1.10 (Country of the counterparty 2) which would have resulted in reports being incorrectly rejected.

Next steps

The finalised Q&As from the first and second consultations have now been published[3].

You should review the published Q&As and incorporate the guidance into your UK EMIR reporting arrangements where necessary.