EMIR Inter-TR reconciliations in the EU and UK: what firms need to know ahead of April and September deadlines

Two years on from the go-live of EMIR Refit, additional Inter-TR (trade repository) reconciliation requirements are coming into force for firms operating under EU EMIR and UK EMIR. The upcoming EU deadline at the end of April is followed by the UK in September.

EMIR Refit’s reconciliation requirements were introduced in a phased approach:

• Phase 1 fields – went live at the start of EMIR Refit (approx. 80 fields)

• Phase 2 fields – two years on from go-live, a further 61 fields, bringing the total number of reconcilable fields to 148.

What are Inter-TR reconciliations?

Inter-TR reconciliations require trade repositories to compare derivatives reports submitted across different TRs to ensure consistency between counterparties for the same trade. Where both sides of a trade are reported to different repositories, regulators expect certain data fields to match.

Many of these additional ‘phase 2’ fields, particularly valuation and lifecycle-related data, bring stricter matching requirements, with many requiring exact alignment between counterparties.

In practice, this means more data to get right, less tolerance for differences, and a much higher likelihood of reconciliation breaks if firms are not fully aligned.

Why this matters now

Regulators have been clear that data quality remains a significant issue, and that they are using EMIR data (and that of other regulatory reporting regimes) not just to detect systemic risk but for a much wider set of supervisory measures and policies. Pairing rates, field consistency, and lifecycle reporting often fall short of regulatory expectations which is consistent with the outcomes seen in our own testing of hundreds of firms’ data.

Inter-TR reconciliation is designed to address this by:

• Identifying mismatches between counterparties
• Highlighting systemic data quality issues
• Increasing transparency across the reporting ecosystem.

For firms, this introduces a new level of visibility. Errors that may previously have gone unnoticed internally will now be surfaced externally.

Key challenges firms will face

• Data alignment across counterparties

With a significantly expanded data set under EMIR Refit, aligning reporting interpretations across counterparties becomes more complex. Even small differences, such as formatting, timing, or field population, can result in reconciliation breaks.

• Lifecycle event consistency

Lifecycle events remain a key challenge. Amendments, compressions, and terminations must now be reported consistently across both sides of the trade and across repositories.

As more lifecycle-related fields are brought into scope for reconciliation, firms without strong controls in this area are likely to see a growing volume of breaks.

• UTI and pairing accuracy

Accurate UTI generation and sharing is critical. Failures here will directly impact pairing rates, which underpin successful reconciliation. Firms should not assume that existing UTI processes will hold up under increased scrutiny.

• Operational readiness

Inter-TR reconciliation introduces new workflows, including exception management and remediation. With a larger volume of reconciled fields, firms should expect a corresponding increase in breaks particularly in the early stages. Clear ownership, prioritisation frameworks, and scalable processes will be essential.

What does good look like?

Firms that approach inter-TR reconciliation effectively will focus on three key areas:

• Proactive testing of data to catch issues before submission
• Counterparty engagement to align on reporting approaches
• Structured exception management to investigate and resolve breaks efficiently.

Final thoughts

Inter-TR reconciliation is a clear signal that regulators are moving towards a more data-driven, holistic view of reporting compliance. For firms, the challenge is no longer just to report but to report consistently, accurately, and in alignment with counterparties. With deadlines fast approaching, now is the time to ensure that reconciliation processes are robust enough to stand up to this new level of scrutiny.

Kaizen’s Completeness Controls provide a comprehensive, independent reconciliation from source system data to reports made to end points, covering eligibility, reportability, pairing and matching, and timeliness. Contact us for a demo of our platform or for a conversation with Tim or one of our regulatory experts.