The go-live is over. The challenge now is proving that derivatives reporting is accurate, timely and properly controlled.
A derivatives report can pass a trade repository’s validation checks and still describe the trade incorrectly. A termination reported as a modification, for example, may leave an inaccurate record of an outstanding exposure. Successful transmission alone does not establish compliance.
The revised EU EMIR reporting technical standards became applicable on 29 April 2024. In 2026, firms should be looking beyond implementation to ask whether their reporting arrangements consistently produce information they can trust and explain.
For compliance officers, reporting specialists, operations teams, risk managers and those overseeing outsourced reporting, this is a practical challenge. Who owns an exception? Can the reported valuation be traced to its source? How does management know that recurring errors have been resolved?
The European Market Infrastructure Regulation (EMIR) requires in-scope derivatives reporting. The revised reporting framework introduced more granular, standardised data requirements, supported by ISO 20022 XML schemas, validation rules and reconciliation tolerances.
The distinction between the legislative reform and its reporting implementation matters: EMIR REFIT predates 2024, while the revised reporting technical standards became applicable on 29 April 2024. For firms reviewing their arrangements in 2026, the task is to maintain effective reporting under that framework and monitor subsequent regulatory guidance and technical updates. ESMA’s EMIR reporting framework.
The underlying obligations remain essential. Reports must be submitted within the applicable deadline, contain correct information and avoid duplication. Article 9 also expressly requires entities subject to the reporting obligation to have appropriate procedures and arrangements to ensure reporting data quality. EMIR Article 9
Firms should also distinguish REFIT trade-repository reporting from separate developments under EMIR 3. Counterparties subject to the Active Account Requirement have reporting obligations under Article 7b. Those obligations require their own assessment and should not be confused with routine Article 9 reporting. ESMA’s reporting guidance and templates
Validation checks help identify reports that do not meet specified technical or logical requirements. They cannot establish that every accepted report faithfully represents the underlying transaction.
Consider a hypothetical investment firm reporting an early termination. Its reporting engine produces a valid XML message, but the source system has classified the transaction as a modification. The message may satisfy relevant validation checks while misrepresenting the economic event.
The control failure began before submission. Correcting the reporting engine alone may therefore leave the underlying problem unresolved.
ESMA’s Report on Quality and Use of Data 2024, published in 2025, illustrates the implementation challenge. Record-level rejection rates reached approximately 20% at REFIT go-live and subsequently declined to between 1% and 2.5%. ESMA and national competent authorities nevertheless identified a supervisory expectation that rejection rates should be close to or equal to zero. These are historical record-level figures, rather than current 2026 rates or file-level rejection statistics. ESMA’s report, p. 23
A low rejection rate is useful evidence, but it is only one part of the picture. Firms also need to assess completeness, timeliness, economic accuracy and unresolved reconciliation differences.
EMIR reporting often crosses several teams. Operations understands the transaction, Technology maintains the systems, Compliance interprets obligations, and an external provider may submit the report.
Problems arise when those responsibilities meet without a clear process for resolving exceptions.
Imagine a valuation difference appearing in repository feedback. The reporting provider confirms that it transmitted the supplied figure. Operations believes the issue concerns a system calculation. Technology sees no processing failure. Compliance receives a monthly exception total, but no explanation of the unresolved difference.
Each team may have completed its assigned task, yet the reporting problem remains.
Each exception should have a named owner, an investigation deadline and a defined escalation route. A designated reporting owner can coordinate controls across the process, supported by clear responsibilities for the teams supplying, transforming and reviewing data.
That internal structure must reflect the applicable legal responsibilities. Voluntary delegation does not remove the duty of the entity responsible for reporting to ensure correct reporting without duplication. EMIR also allocates responsibility in specific circumstances, including certain financial-counterparty reporting arrangements with non-financial counterparties below the clearing threshold, and arrangements involving UCITS management companies and AIFMs. An internal ownership chart should reflect these distinctions. EMIR Article 9
A report’s journey begins well before it reaches a trade repository. Information may pass through trade-capture systems, reference-data sources, valuation platforms, collateral systems, reporting engines and external providers.
Effective oversight requires an understanding of that journey.
If a reported valuation is challenged, the firm should be able to identify its source, the relevant calculation or transformation, and the basis for the submitted figure. Firms should also trace counterparty identifiers and lifecycle reporting data to their sources.
Checks closer to the source can help prevent avoidable errors. Depending on the reporting process, these might flag missing identifiers, inconsistent event information or unexpected changes in reported values before submission.
Such controls are practical measures for supporting reporting accuracy; they should not be presented as a prescribed technology model. Firms need controls proportionate to their activities and reporting arrangements, with evidence that those controls work.
A useful review goes beyond asking how many reports were accepted. Compliance and reporting teams can start with five questions:
1. Is responsibility clear?
Can staff identify the legally responsible entity, the submitting provider and the internal owner of each reporting control?
2. Are exceptions investigated and resolved?
Does monitoring show recurring issues, aged reconciliation breaks, their causes and the progress of corrective action?
3. Can reported data be traced to its source?
Can a sample trade be followed from execution through subsequent lifecycle events to the repository record?
4. Is delegated reporting actively overseen?
Does the firm receive enough information to assess timeliness, completeness, errors and remediation, and challenge its provider where necessary?
5. Are escalation arrangements understood?
Do staff know how to assess an issue, correct affected reports and determine whether notification to the competent authority is required?
These questions form a starting point for a control review, rather than an exhaustive compliance checklist. ESMA’s reporting framework includes guidance and supporting documentation on validation, reconciliation and notification of reporting errors and omissions. ESMA’s EMIR reporting resources
Management reporting should make these controls visible. Alongside acceptance and rejection rates, useful measures can include late submissions, unresolved breaks, repeated errors, remediation time and the results of sample-trade reviews. Measures need interpretation: a falling exception count is encouraging only if issues have been corrected and the monitoring remains effective.
Firms with EU and UK reporting responsibilities should maintain a clear distinction between the two frameworks.
Most revised UK EMIR reporting requirements became applicable on 30 September 2024. On 16 April 2026, the FCA updated its validation rules, including setting 28 September 2026 as the reconciliation start date for specified fields previously described as starting two years after the reporting obligation began.
That date has now passed. Firms with relevant UK obligations should check that their reporting and reconciliation arrangements reflect the applicable changes. The UK update should not be treated as an EU REFIT deadline. FCA’s UK EMIR updates
ESMA’s annual data report published in May 2026 highlights improvements in regulatory data quality and growing supervisory use, alongside increased automation, analytical tools and shared dashboards. For firms, this reinforces the value of reporting that is accurate and explainable. ESMA’s 2026 publication
A practical exercise is to select sample trades and bring Compliance, Operations, Risk and Technology together to reconstruct their reporting journey. Include a lifecycle event, a valuation change and, where relevant, a delegated submission.
Can the team explain the reported information, identify the controls applied and show how any error was resolved? Where the answer depends on undocumented knowledge or repeated hand-offs, the exercise has identified an improvement opportunity.
Staff reviewing validation results need to interpret exceptions and identify inaccurate reports. Practical training can help staff investigate reporting errors and apply the requirements consistently.
Explore EIMF’s financial regulation training to support the knowledge and practical skills behind effective EMIR reporting.
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