What the Industry Learned at our Breakfast Briefing on Market Watch 84 & EMIR Refit Reporting

Last week, Kaizen brought together more than 300 regulatory reporting professionals – both in person and online – for a deep-dive into Market Watch 84, the recently published UK EMIR Reporting Q&As and the implications for EMIR Refit reporting. With representatives from both the supervisory and policy sides of the UK regulatory landscape joining the discussion, the session offered a direct look at evolving expectations for EMIR reporting.

While the conversation took place under the Chatham House Rule, several clear themes emerged. Below we summarise the key messages and practical takeaways for firms navigating the next phase of EMIR Refit.

Data quality is a strategic priority, not a technical issue

A consistent thread throughout the discussion was the critical importance regulators place on data quality. EMIR data is used widely across supervisory, policy and market-monitoring functions. The message was clear:

EMIR data feeds directly into senior decision-making
Poor reporting undermines supervisory insight
Data quality issues are no longer viewed as operational noise – they impact policy outcomes.

The move to XML and the Refit schema has already improved baseline quality but regulators expect firms to keep raising reporting standards. Data quality is now a leading regulatory risk, not a back-office technical issue.

The Refit implementation was a success and provided essential lessons too

Both regulators and industry should take confidence from the smooth transition to the new regime under EMIR Refit. Day-one reporting was strong, and the majority of firms completed their six-month uplift window on time.

However, there were also lessons learned during the implementation phase:

Reliance on third-party vendors increased sharply during this time, bringing with it gaps in oversight and testing
Some firms struggled to manage competing regulatory projects, especially those with dual EU/UK obligations
The uplift to the new regime had removed a small but significant population of “zombie” trades, highlighting weaknesses in historical data hygiene.

Error and omission reporting: more transparency, better governance

One of the key themes in the discussion concerned error notifications. Error reporting should not be viewed negatively and is increasingly a sign of:

Strong controls
Clear governance
A willingness to be transparent.

However, what may be viewed negatively is the absence of notifications where errors clearly exist.

The important points for firms to note are:

There is no fixed threshold for materiality – volume alone is not sufficient to determine significance
Firms should take a ‘cautious’ approach to submission – if in doubt, submit. The regulators will communicate with firms if they think their materiality thresholds are not appropriate.
Initial submissions can be updated over time, but timeliness is important
Quality of narrative can be poor – firms should improve clarity, completeness and consistency.

Error and omission reporting is now an important part of supervisory dialogue. Firms who avoid it are drawing the wrong conclusion about how it is perceived.

Change management remains a weak spot across the industry

Despite long preparation windows, many reporting issues stem from weak change-management practices:

Insufficient oversight of third-party providers
Inadequate testing of mapping and judgements
Limited visibility of delegated reporting outputs
Dependencies / overlap between EU and UK projects causing resource pressures.

Firms should now consider the following:

Refresh their change-management frameworks
Perform structured post-implementation reviews
Revisit testing strategies and reconciliation approaches
Ensure they have trade repository (TR) access and can independently validate completeness and accuracy.

Q&A updates bring clarity on technical ISINs and FX swaps

The recent UK EMIR Q&A update addressed two longstanding pain points.

Technical ISINs

A new “technical ISIN” is now available for scenarios where underlying instruments lack an issued ISIN. This prevents firms from failing validation rules and, crucially, enables regulators to identify where gaps in global ISIN coverage exist.

Use is strictly limited to the specified scenarios. This is not a workaround for convenience, and firms should apply it cautiously.

FX Swaps Clarification

Perhaps the most welcome update was the long-awaited clarity on FX swaps:

If a single instrument is executed, confirmed and settled as a swap, it should be reported as one instrument
Where a near-leg and far-leg are executed as separate contracts, only the eligible components should be reported, typically the forward leg, unless both legs fall within the spot window (in which case no reports are required).
Package fields should be populated even where the spot leg is not reportable.

This clarity is expected to significantly improve pairing, matching and overall data quality across the FX landscape.

Pairing and matching are now in the spotlight

With Phase 2 reconciliation rules coming into effect next year, pairing and matching rates are receiving closer attention.

Key points:

Pairing should approach 100%, even if not fully achievable in practice.
Firms should be actively collaborating with peers to resolve UTI, lifecycle and population mismatches.

Firms that are not already analysing their reconciliation performance, both bilaterally and via vendor tools, should prioritise this now.

Looking ahead: expect more collaboration, not less

The UK EMIR Reporting Industry Engagement Group, used heavily during the Refit rollout, will continue and will be used to maintain an open channel with industry and to:

Shape future Q&A
Identify areas of ambiguity
Improve pairing and matching
Support industry-wide operational alignment
Prepare for the 2026 reconciliation phase.

Conclusion

EMIR reporting has entered a new phase with the focus having shifted from implementation to ongoing accuracy, demonstrable governance and proactive issue management.

For firms, this means:

strengthening internal controls
scrutinising vendor-led reporting
investing in reconciliation and data validation
engaging early and transparently with supervisors and regulators
gearing up for the 2026 reconciliation expansion.

The industry has made real progress but expectations are rising across the industry.

For a conversation with one of our subject matter experts or a free health check of your EMIR Reporting please get in touch.