The UK Financial Conduct Authority (FCA) has introduced changes making the field ‘Execution Agent’ a conditional field to report under EMIR. The new requirements transaction reports are reflected in the EMIR Technical Standards on reporting through Handbook Notice No 132 and updated EMIR validation rules and XML schema. These new validation rules will take effect from 26 January 2026 (Implementation Date).
What is the ‘Execution Agent’ and what exactly are the changes?
The ‘Execution Agent’ field identifies the party that executes a trade on another’s behalf. Given this is currently an optional field and firms have been voluntarily completing this field, making it conditional will improve data quality and consistency amongst the trade repositories and transparency of executed transactions. The changes apply to Table 3 for margin reporting and Table 1 for transaction reporting.
Those counterparties that use brokers or third parties to execute their trades will be required to capture and report the LEI of that third party in a timely manner.
The FCA consulted earlier in 2025 as part of its Quarterly Consultation CP25/16 in which they looked into the ‘Execution Agent’ field. ISDA also showed support for the amendments to the Technical Standards.
Is there enough time to prepare?
Given there are other reporting changes scheduled for 2026, industry should act early to avoid any operational bottlenecks. There is only a short time to prepare; however, this should be a fairly easy change to implement.
The original date for implementation was suggested as being 1 December 2025 ;however, feedback from reporting firms suggested this would not be enough time for implementation. It was also highlighted that FCA reporting participants may be impacted by the Reconciliation Phase 2 go-live in April 2026.
How can TRAction assist?
If you need any assistance with your current trade reporting set up, understanding new regulatory requirements like new fields being required for reporting or need a delegate trade reporting service provider, please do not hesitate to contact us.
