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Following the introduction of the amended reporting rules detailed in PS23/2 there has been a 6-month period for counterparties to update their outstanding derivative reports to comply with the new requirements. When this transition period ends, market participants that have not updated all outstanding derivative reports risk being in breach of their reporting obligation for affected trades. We encourage all counterparties to review their arrangements and ensure that they have taken the necessary steps to amend their outstanding derivative reports ahead of 31 March 2025.
Where firms identify that they may be at risk of failing to amend their outstanding derivative trades ahead of this date, we expect entities responsible for reporting to proactively engage with us and provide an explanation as to why they are unable to comply with the new requirements.
Please also be aware that following the end of the transition period, all XML schemas will be ‘strict’, meaning that only reports consistent with the new requirements will be allowed to be reported.
For further guidance on our expectations for the end of the transition period, please see section 1 of our UK EMIR reporting Q&As.
For any enquiries or to speak to us about issues with updating outstanding trades, please email EMIRreporting@fca.org.uk
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