Whilst ESMA’s EU EMIR Refit has been finalised with a go-live date of 29 April 2024 for some time, the FCA has only recently published the final rules for UK EMIR Refit with a reporting start date of 30 September 2024.
The UK’s FCA has adopted most of the EU’s EMIR Refit regulation which has been published by ESMA. The major changes introduced are broadly aligned (see the FCA’s consultation paper CP21/31), for example UPI requirements, the introduction of global logic structure for UTI and the number of new fields being introduced (see our previous EMIR Refit article).
The FCA has also released the draft validation rules which contain a list of fields that diverge from ESMA, mainly due to a different version of the XML schema published by ESMA.
Overall there are not many variations in the validation rules for UK EMIR Refit compared with EU EMIR Refit. However, as the go-live dates are different, this might cause some added complexity for firms with dual obligations (i.e. where they are reporting under both ESMA and the FCA).
Over time it is likely that these two schemes will further diverge. As such, TRAction considers it crucial that firms build their reporting systems separately for UK and EU EMIR Refit reporting.
Given the scale of operational challenges, firms need to start preparing for all these changes now – and be ready for future changes too.
Contact us if you would like to know more about how to simplify your reporting.