The FCA has published Market Watch 84, reviewing the implementation of UK EMIR Refit one year on. While most firms managed the transition, the newsletter highlights continuing weaknesses in reporting resilience, vendor reliance, and error management.
Implementation progress, but gaps remain
The FCA reports that 95% of trades were successfully uplifted to the new format by the March 2025 deadline. However, a significant minority of firms did not meet the cut-off, leaving trades non-reportable and breaching obligations. The regulator’s message is clear: reporting is not a one-off project, it demands ongoing governance, oversight and accountability.
Vendor dependence under scrutiny
A central theme of Market Watch 84 is reliance on third-party vendors. Many firms outsourced uplift work but encountered issues with data mapping, schema logic and enrichment. The FCA emphasises that outsourcing does not transfer responsibility: firms remain accountable for timely, accurate and complete reporting.
This point links directly back to Market Watch 81, which warned that poor change management, weak controls and limited oversight were among the root causes of misreporting. Vendor use can magnify these weaknesses when firms fail to exercise effective oversight.
Errors and omissions – a persistent challenge
Since EMIR Refit went live, 267 reporting issues have been notified to the FCA, far fewer than expected given market size. The regulator suspects under-reporting, as firms interpret “materiality” inconsistently.
Here, the guidance from Market Watch 82 is highly relevant: firms should notify early, remediate root causes first, and provide updates as more information becomes available. Transparency is always preferable to delay or silence.
What comes next
Over the next 12 months, the FCA will focus on reconciliation quality, breach notifications and firms’ ability to correct errors in both live and matured trades. Firms are encouraged to review vendor oversight, governance arrangements and remediation processes now to avoid supervisory challenges later.
How MAP FinTech can help
At MAP FinTech, our solutions deliver automation, robust mapping, validation, and enrichment. Powered by the Polaris Platform, they cover the full reporting cycle, from data sourcing to submission and monitoring, adapting quickly to regulatory change. We also address the FCA’s concerns on reporting processes, vendor reliance, and error management by combining technology with oversight and remediation support, giving firms greater confidence, control, and resilience.
Be prepared. Be transparent. Stay ahead with MAP FinTech.
