What is EMIR Refit Transaction Reporting?

EMIR Refit (European Market Infrastructure Regulation Refit) is the mandatory regulatory update to the existing EMIR transaction reporting rules, which requires financial firms to report their over-the-counter (OTC) derivatives transactions in the EEA (European Economic Area).
ESMA published their 2024 Report on Quality and Use of Data on Data Quality on 30 April 2025, which provided an idea of progress a year on from implementation. In summary, data quality has improved with most metrics recording drops in breaches or exceptions – although ESMA notes there is still progress to be made. The FCA has not released a similar report.

Contact Qomply

Former FCA regulator, Sophia Fulugunya discusses the challenges firms face with EMIR Refit Transaction Reporting requirements.

About EMIR Refit

The European Market Infrastructure Regulation (EMIR) covers derivatives, central counterparties and trade repositories (TRs) and was initially adopted in 2012. The amended version, EMIR Refit, was adopted in 2019. Following Brexit, there are now UK EMIR and EU EMIR regulations. The new rules under EMIR Refit came into effect on 29 April 2024 for EU entities and 30 September 2024 for UK entities.

The publication of the EMIR Refit changes supported the main purpose of the original EMIR, which was to reduce systemic, counterparty and operational risk whilst increasing transparency in the OTC derivatives market. It also aimed to improve the data quality received by regulators, provide clarity to firms where required, and streamline the registration process for TRs.

Who will be primarily affected under 2024 EMIR Refit?

  • Counterparties in scope of the reporting requirements under EMIR Refit
  • TRs registered, or recognised, under EMIR Refit
  • Third party service providers who offer reporting services to counterparties subject to reporting under EMIR Refit

What are the changes under 2024 EMIR Refit?

  • More reporting fields: Increase in the number of reportable fields from 129 to 203. A small number of fields have been removed, such as “Trade capacity”.
  • Change in reporting format from CSV to XML: ISO20022 standard, the open global standard for financial information, requires EMIR reports to follow standardised XML structure.
  • Unique Trade Identifier (UTI): For derivatives reports concluded after the effective date, a specific UTI code will be used to update the state of these reports.
  • Unique Product Identifier (UPI): UPI will be required to report most derivatives trades and must be present in the Derivatives Service Bureau (DSB) database.

FAQ: EMIR Refit Transaction Reporting / EMIR Refit

EMIR Refit transaction reporting covers all derivate contracts, regardless of whether they are OTC derivatives or exchange-traded derivatives. Subject to certain exceptions, both sides of the trade report data that must be matched in a TR.
Financial Counterparties (defined by EMIR Article 2(8) as a regulated financial institution, e.g., banks) must report their own transactions, as must Non-Financial Counterparties (NFC) (defined as anything not a Financial Counterparty, e.g., corporates) above the clearing threshold for that particular type of derivative. The clearing threshold figure is based on the gross notional value of outstanding non-hedging OTC derivative contracts across all group entities. Where the clearing threshold is not met, small NFCs do not report and the Financial Counterparty on the other side will report on their behalf. Intra-group trades are exempt from reporting requirements if at least one side of the trade is an NFC and certain other conditions are met.
Unlike most transaction reporting regimes, EMIR Refit reporting is double-sided. This means that each counterparty to a derivative trade has a reporting obligation, rather than the reporting counterparty being determined by a reporting hierarchy.
At a high-level, in addition to seeking to provide higher quality information for regulators, EMIR Refit sought to reduce the obligations and burdens on smaller financial counterparties by introducing a clearing threshold. It has also sought to do this for non-financial corporates, where the clearing threshold is now assessed per asset class, rather than on an all or nothing basis.

EMIR Refit 2024 Updates Timeline

7 Oct 2022

EMIR Refit technical standards published in the official journal

20 Dec 2022

ESMA publishes final reporting guidlines, validation rules and reporting instructions

24 Feb 2023

FCA publishes final reporting rules

29 April 2024

EU EMIR Refit goes live

30 Sep 2024

UK EMIR Refit goes live

Rely On Qomply To Help

Qomply has a variety of solutions to help firms comply with their regulatory EMIR Refit reporting obligations:

QomplyEngine generates EMIR REFIT transaction reports

QomplyEngine - Generate Transaction Reports From Raw Data


Builds transaction reports from raw data points and save resources and hassle by offloading transaction report generation
Quality Assurance for Transaction Reports

Diagnostic Auditor - Ensure Reports Are Accurate


Apply over 1,000 accuracy checks and scenarios across your Transaction Reporting in a click
QomplyDirect send reports directly to the FCA

QomplyDirect - Submit Reports Directly to Regulator


Send Transaction Reports directly to the regulator bypassing the need to use an ARM thus reducing costs and improving efficiency
Outsource your EMIR REFIT Report Operations

Qomply Managed Services - Delegate Your Transaction Reporting Operations to Qomply


Qomply Managed Service alleviates the burden of technical expertise but also provides peace of mind that regulatory requirements are being met in a risk-free and cost-effective manner

Free EMIR Resources

● EMIR Refit: Conventions & Fields That Require a Closer Look
● Recognition of TONA Index
● Reporting Tracking Number is not a TVTIC
● MIC Code Used for Third Country Venues
● Reporting FX Swaps
● Client Codes should not contain personal data
● Top 5 Challenges for Regulated Firms

External Resources

● EMIR Reporting | ESMA
● UK EMIR | FCA
● UK EMIR library | FCA
● UK EMIR Reporting obligation | FCA

More Reporting Regimes

● MiFID II Transaction Reporting 101
● MiFID II Post-Trade Reporting 101
● CFTC Transaction Reporting 101
● CSA Transaction Reporting 101
● MAS Transaction Reporting 101
● SFTR Transaction Reporting 101
● ASIC Transaction Reporting 101

Request a Demo

Let's Get In Touch!

Want to know more or just want to phone us up for a chat?

+44 (0)20 8242 4789

info@qomply.co.uk

Qomply

© Copyright 2025 Qomply

Qomply is the trading name of Qomply Limited and is a private limited company registered in England and Wales with registered number 12082474, VAT Number 357 7105 86 and registered address: 133-137 Fetter Lane, London, EC4A 1BF, UK.