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The European Market Infrastructure Regulation (EMIR) Refit is an EU regulation intended to increase transparency and reduce risk in the derivatives market. With the updated standards now firmly embedded within the industry, we are starting to see feedback from both the EU and UK regulators, as well as data quality and rejection trends. Given that a key focus of the regulatory changes is the harmonization of reporting standards to enhance data quality, it鈥檚 important that reporting firms digest industry feedback and align it with their own reporting processes and systems.

Why it matters

Regulators are no longer only checking whether firms submit reports; they are testing the quality of the data itself. Recent fines from European regulators, including a 鈧�192,500 penalty in Ireland for EMIR reporting failures and six-figure sanctions against trade repositories by ESMA, show poor data quality has direct financial consequences. Beyond the fines, rejected submissions mean costly remediation and wasted resources that could be directed toward clients and growth.

ESMA鈥檚 Review: Signs of progress, but work ahead

The European Securities and Markets Authority (ESMA) published its own data quality report at the end of April 2025, which summarized key reconciliation trends.

• UTI matching has improved. As of December 2024, where both parties have an EU reporting obligation, there were signs of improvement in the post-reporting reconciliation results. Just over 20% of reported derivatives were missing a corresponding Unique Transaction Identifier (UTI). This is reduced from 33.91% in May 2024 just after the Refit went live, and over 40% pre-Refit.
• Stale valuations remain a problem. Again, the trend is towards improvement. With this, the number of derivatives with stale or missing valuation was 16.19% at the end of 2024 vs 30% mid-2024.

Summary: Progress is happening, but the industry still has work to do. Data quality is improving, but it is not yet where it needs to be.

UK regulators tighten oversight

With the UK EMIR Refit being only a few months out of the transition period at the end of March, the FCA has not released any pairing and matching information. However, the FCA has made it known that it would closely monitor firms during this period and may use supervisory powers in a 鈥減roportionate and risk-based鈥� way where necessary.

In addition, the FCA has already looked into tweaking the reporting standards regarding both the Executing Agent field and the Unique Product Identifier (UPI) requirement.

Industry pushback and system strain

Industry participants and the Trade Repositories have noted a big shift post-Refit. A wider variety of End of Day Reports are available post-Refits, providing greater granularity to both reporting firms and regulators. In theory, this additional transparency further empowers firms to create robust, control-based reporting solutions. They also increase expectations from regulators and NCAs on firms in terms of reporting quality.

In addition, the new reporting standard鈥�with its increased number of data points in a transaction report and greater instrument-level granularity鈥�has created further strain on firms to allocate important resources dedicated to the EMIR reporting requirement.

What firms need to do next

The direction of travel is clear. Regulators expect:

• End-to-end oversight of reporting processes.
• Strong controls to prevent errors before submission.
• Post-reporting monitoring to maintain ongoing data quality.

In the coming months, as we begin to get further feedback from ESMA and the first UK data quality reports, it will only emphasize what is becoming clearer firms must have strict end-to-end controls over their reporting processes and even greater post-reporting oversight and control functions.

If your team is still grappling with rejections, stale valuations or stretched resources post-Refit, now鈥檚 the time to act. At 天美传媒, we help firms design transparent, scalable reporting solutions that meet today鈥檚 regulatory demands and adapt for tomorrow.

Contact us to talk about how we can help you raise your reporting standards with confidence.