1: Introduction
This policy statement (PS) provides a summary of the feedback received to the consultation paper (CP) regarding our proposed amendments to the UK EMIR Trade Repository reporting requirements. It also sets out our response to the feedback and the finalised rules (Appendix 1).
Under Article 9 of UK EMIR, the Bank of England (the Bank) and Financial Conduct Authority (FCA) (together, ‘the Authorities’) share supervisory responsibilities for the derivatives reporting obligation. The Bank is responsible for the framework for derivatives reporting as it applies to central counterparties (CCPs). The FCA is responsible for the reporting framework for all other counterparties. Any subsequent references to ‘we, ‘us’ and ‘our’ in this PS should be read in this context and based on this split of responsibilities.
1.1: Background
Following the completion of the implementation of UK EMIR Refit in March 2025, in the light of feedback from industry, we consulted on two proposed amendments to the Bank Standards Instrument: The Technical Standards (EMIR Reporting and Data Quality and Miscellaneous Amendments) Instrument 2023 to provide greater clarity to the requirements, and to minimise workarounds for reporting entities.
In developing the proposals, the Bank considered its objective to protect and enhance the financial stability of the UK, its statutory obligations, and other relevant considerations, including the Bank’s considerations on the costs and benefits of the proposals. The Bank considers that its approach would not place an undue burden on firms and that the approach is aligned with the Bank’s financial stability objective.
The Authorities have considered the responses made during their consultation and are publishing feedback to those responses in this PS.
1.2: Who this affects
This PS will primarily affect:
- counterparties in scope of the reporting requirements under UK EMIR;
- Trade Repositories (TRs) registered, or recognised, under UK EMIR; and
- third-party service providers who offer reporting services to counterparties subject to UK reporting under UK EMIR.
This PS may also be of interest to trade associations, law firms and consultancy firms.
1.3: Summary of responses
We received ten responses to the consultation. Respondents included reporting counterparties, trade repositories, trade associations, trading venues and central counterparties (see Appendix 2).
All respondents supported the substance of the proposed changes. However, feedback was split regarding the implementation date. While seven respondents supported the proposed implementation date of 1 December 2025, three respondents – all of them trade repositories – requested a longer implementation period.
1.4: Changes to proposed amendments
The implementation date of our final rules has been changed to 26 January 2026 in response to feedback. The other elements in our original proposals are largely unchanged. The minor changes relate to validation rules and are set out in section 2.4.
1.5: Implementation
The Bank is amending the Bank Standards Instrument: The Technical Standards (EMIR Reporting and Data Quality and Miscellaneous Amendments) Instrument 2023 using the Bank’s powers under Article 9 of UK EMIR and under section 138P of the Financial Services and Markets Act 2000 (FSMA).
The Bank has consulted with both the FCA and the PRA pursuant to Section 138P(4) of FSMA ahead of making the standards instrument.
The Bank has also sought and received approval from HM Treasury to make the standards instrument.
The final standards instrument in the appendix has now been made. The amendments come into force on 26 January 2026.
We have published alongside this PS the final Validation Rules (applicable from 26 January 2026) and XML reporting schemas: Incoming messages to TRs and Outgoing messages from TRs (applicable from 26 January 2026) to support industry implementation.
2: Feedback to responses
This section summarises the feedback received on the CP, and our response.
2.1: Proposal 1
Addition of ‘Execution agent’ as a new field, Field 30, in Table 3 of the Annex of each reporting Technical Standards, and the consequential cross-referencing changes in the Technical Standards.
Summary of feedback received:
We received nine responses to this proposal. All respondents agree to the proposed addition of Field 30 (Execution agent) to Table 3 of the Annexes of each technical standard.
Our response:
Having considered the feedback received, all respondents agree to the proposed addition of Field 30 (Execution agent) to Table 3 of the Annexes of each technical standard. We will therefore proceed with the proposal as set out in the CP.
2.2: Proposal 2
The amendment of Article 8 (‘Unique Transaction Identifiers’) of Annex B (Technical Standards on the Standards, Formats, Frequency and Methods and Arrangements for Reporting) of the Technical Standards to correct a cross-referencing error.
Summary of feedback received:
Two respondents supported Proposal 2.
Our response:
We have considered the feedback received and will proceed with this proposal as outlined in the CP.
2.3: Feasibility of Implementation date of 1 December 2025
Summary of feedback received:
We received ten responses regarding the implementation date of these proposals. Of these responses, seven supported the implementation date of 1 December 2025 as an appropriate and reasonable period in which to undertake implementation. Of the responses in support of the implementation date, two respondents – both trade associations – highlighted that the implementation date of 1 December 2025 should be conditional on the final Technical Standards, Validation rules and XML Schemas being published at least three months prior to the implementation date.
Responses from reporting counterparties agreed that the 1 December 2025 implementation date allows adequate time for firms to make this change to their reports given that the proposed field already exists in other Tables of the Annexes of each technical standard.
Three respondents – all of them trade repositories – requested a longer implementation period. Two of these respondents suggested a minimum six-month implementation period from the publication of the final rules. One respondent highlighted that there are holiday periods (such as Thanksgiving) which coincide with the proposed implementation period. During these holidays there will likely be change freezes, which may impact industry readiness, they therefore suggested an implementation date of 2 February 2026.
One trade repository highlighted that FCA-reporting participants may also report to ESMA and will be impacted by the Reconciliation Phase 2 go-live in April 2026, they therefore suggested to avoid implementing our proposed rules in the preceding months.
Our response:
We have considered the feedback received that some respondents disagree with the implementation date of 1 December 2025. We note some respondents suggested a longer implementation period commencing from the publication of the final rules rather than six months from the June publication of the CP.
We recognise that despite the Execution Agent being an existing optional field, the addition of the execution agent field will require changes to reporting systems. We note the feedback from the majority of trade repositories that this change will require a period of industry testing which, without adequate time to complete due to year end change freezes, may impact industry readiness.
We acknowledge that feedback from reporting firms supported our original proposed implementation date of 1 December 2025. However, due to the majority of trade repositories requesting an extended implementation period, we have amended the implementation date to 26 January 2026. While this is almost six months from the publication of the final rules, this date reflects the request to mitigate the impact of industry change freezes, rather than a default need for a six-month implementation period.
2.4: Other feedback received
Alongside the consultation on proposals 1 and 2, we also asked for comments on proposed changes to the Validation Rules.
We note the support for the validation rule changes made to fields 5 (PTRR ID) and 45 (Early Termination Date) within Table 2.
Our response:
We will therefore proceed with these proposals as originally set out.
We also note the feedback requesting additional amendments to the Validation Rules to avoid rejections based on the status of the Execution Agent LEI in both Tables 1 and 3.
Our response:
We have incorporated these amendments into the final Validation Rules (applicable from 26 January 2026) and XML reporting schemas: Incoming messages to TRs and Outgoing messages from TRs (applicable from 26 January 2026).
2.5 Responses out of scope of the CP
There was also feedback on further schema changes that fall outside the scope of the current proposals, along with requests for clarification on the validation rules for field 2.1 ‘UTI’.
Our response:
While the additional schema changes and clarification requests are beyond the scope of this consultation, we acknowledge the feedback and may consider these changes in the future.
Appendices
Appendix 1: Bank Standards Instrument: The Technical Standards (EMIR Reporting and Data Quality and Miscellaneous Amendments) Instrument 2025
Appendix 2: List of respondents
DTCC Derivatives Repository Plc
ICE Clear Europe
ICE Trade Vault Europe Limited
International Swaps and Derivatives Association (ISDA)
LSEG Regulatory Reporting Trade Repository
Plus500UK Ltd
Regis-TR UK Ltd
SimplyBiz Services Limited
The Futures Industry Association (FIA)
The Investment Association