The Bank of England (BoE) made amendments to UK EMIR reporting requirements following intense lobbying by trade repositories (TRs), who warned that the original timetable clashed with end-of-year change freezes, holiday staffing gaps and overlapping regulatory deadlines in Europe.
The amendments themselves are modest in scope but important in practice. They include the addition of a new “execution agent” data field to derivatives reporting tables, intended to improve transparency in execution chains, and the correction of a long-standing cross-referencing error in the standards for Unique Transaction Identifiers (UTIs). Alongside these, the BoE has adjusted validation rules to reduce the risk of automatic rejections when certain identifiers are inactive, a tweak welcomed by market participants.
“Even incremental updates like these require extensive coordination across firms and markets, particularly given the overlapping international timelines,” said Kirston Winters, head of Legal, Risk, Compliance and Government and Regulatory Affairs at OSTTRA, in emailed commentary. “By aligning the rollout with operational realities, the Bank not only supports a smoother transition but also reinforces the importance of robust and accurate derivatives reporting. This flexibility ultimately benefits market integrity.”
Volker Lainer, vice president of Product Management for Data Integrations, ESG and Regulatory Affairs at GoldenSource, said in emailed commentary: “The BoE’s EMIR tweaks may seem modest in practice, but they go straight to the heart of data accuracy and completeness. Although Unique Transaction Identifiers (UTIs) are important for accurately linking transaction reports across multiple counterparties, their generation and validation remains very complex, particularly when correcting longstanding errors.
“These technical details require extensive testing across multiple systems to avoid data inconsistencies that could undermine market transparency. By extending the timeline even by just an additional month, the Bank not only mitigates operational risks, but also facilitates smoother alignment with EU reporting standards, ultimately enhancing the reliability of derivatives data.”