UK EMIR reporting rules: Back in March 2025, the UK EMIR Refit went live. But as always, once the new rules were tested in the real world, some bumps showed up. One of the biggest issues? An important reporting field—called the “Execution agent”—was left out of the technical annex for margin reporting.
So what happened? Reporters had to use messy workarounds. That’s never a great long-term solution.
Now, the regulators want to fix that by:
- Officially adding the “Execution agent” field into the right section of the rules.
- Correcting a technical referencing error in Article 8 (which deals with transaction identifiers).
What Exactly Is Changing?
Here’s what’s being proposed, starting December 1, 2025:
1. New ‘Execution Agent’ Field
Who it affects: Investment firms and managers that delegate trade execution to a third party (like a broker).
What’s new: A new field—Field 30—is being added to Table 3 of the UK EMIR Technical Standards. This makes it easier and more transparent to report when a third party executes the trade.
Why it matters:
- No more workarounds.
- Easier reporting process.
- Clearer data trail for regulators.
2. Fixing a Cross-Referencing Error
This one’s technical but important: the Unique Transaction Identifier (UTI) reference in Article 8(5) had a typo that confused things.
The fix: They’re correcting the reference so it aligns properly in all reporting documentation.
Why it matters: It eliminates confusion and ensures all documents point to the right place—saving you time (and compliance headaches).
Who Needs to Pay Attention?
If you’re any of the following, this affects you:
- A counterparty under the UK EMIR reporting rules
- A Trade Repository (TR)
- A third-party reporting service provider
- Or even part of a law firm, consultancy, or trade association working in the derivatives space
Basically, if you’re anywhere near UK EMIR reporting—this is on your radar.
When Do These Changes Go Live?
📅 Mark your calendar: December 1, 2025.
That’s when these changes are expected to take effect—assuming all feedback is in and the Treasury approves the final version.
How to Submit Your Feedback (Before It’s Too Late)
The Bank and FCA are actively inviting responses. You’ve got until 30 June 2025 to have your say.
Here’s how:
- CCPs: Email feedback to emirreporting@bankofengland.co.uk
- Others (TRs, firms, providers): Email cp25-16@fca.org.uk
Your feedback matters, especially if you’ve been dealing with these rules day in and day out.
Why This Matters for the Bigger Picture
These changes might feel small—but they’re part of a bigger effort to make reporting smoother, clearer, and more effective.
By cleaning up errors and clarifying the rules, the authorities are:
- Helping reduce compliance burden
- Supporting data transparency
- Enhancing financial system stability
And in a world where markets move fast and risk builds quietly, that clarity isn’t just helpful—it’s essential.
FAQs About the UK EMIR Amendments
1. What’s an ‘Execution agent’ in simple terms?
It’s a third party (often a broker) that actually executes the trade on your behalf. If you use one, you’ll now need to report it in Field 30.
2. Do I have to report this new field if I don’t use an Execution agent?
Nope. It’s optional—only required if you use an execution agent.
3. Is there a big cost to making this change?
Not really. Most firms already collect this data. This update just helps you report it more cleanly—without needing a workaround.
4. What happens if I don’t make the change?
Once the amendment is live, failing to include the Execution agent field when required could mean inaccurate reporting—which might land you in hot water with regulators.
5. What’s the deal with the Unique Transaction Identifier correction?
A referencing error in Article 8(5) caused confusion. That’s now being fixed so all documents are in sync.
6. Will there be more changes like this?
Possibly. The authorities are committed to refining EMIR reporting over time to make it clearer and easier to follow.