EMIR Refit is the biggest overhaul of derivatives reporting in over a decade, and it has changed how firms report derivative contracts. The UK regime went live on 30 September 2024, and it brought more fields, a new file format, new identifiers and tighter expectations from the regulator.
If you report derivatives, the practical question is simple: what actually changed, and what do you need to do about it? Much of the answer comes down to data, format and identifiers, including the Legal Entity Identifier, which sits at the centre of EMIR reporting and which LEI24 helps companies obtain and renew.
What Is EMIR Refit?
EMIR Refit is a major update to reporting under the European Market Infrastructure Regulation (EMIR). REFIT stands for the Regulatory Fitness and Performance Programme, the framework the regulators use to review and improve existing rules.
The aim was to raise data quality, standardise reporting globally and make derivatives data more usable for supervisors. In practice it rewrote large parts of how firms report, rather than adding a few fields at the edges. EMIR itself, the clearing and risk rules and who has to report, is unchanged in principle, so the focus stays on what Refit changed within the wider machinery of regulatory reporting.
EMIR Refit Timeline: Go-Live, T+1 and Backloading
The EU and the UK ran to different dates, which matters for any firm reporting to both.
- EU EMIR Refit went live on 29 April 2024.
- UK EMIR Refit went live on 30 September 2024, five months later.
- Reports remain due by T+1, one working day after the trade.
- Derivatives outstanding on 30 September 2024 had a transition window to update their reporting data into the new Refit format, which ran to 31 March 2025.
Since Brexit, UK EMIR and EU EMIR are separate regimes. They remain broadly aligned, but the staggered dates and small differences in validation mean firms reporting to both carry a dual reporting burden, with the same trade reported under two schemas.
Who Is in Scope?
Under UK EMIR, derivative contracts are broadly reportable, but who reports and how the reporting is handled depends on the counterparties and the transaction. A wide range of firms is in scope, including investment banks, asset managers, hedge funds, insurers and many non-financial companies that use derivatives to hedge. The mechanics matter too: for OTC derivatives between a financial counterparty (FC) and a small non-financial counterparty (NFC-), the FC is responsible for reporting on behalf of both, unless the NFC- chooses to report itself. Because EMIR reports use LEIs to identify legal-entity counterparties and certain other relevant entities, firms in scope often need an LEI to report correctly, so it is worth confirming exactly who needs an LEI number.
FC, NFC and SFC Classifications
Your reporting and clearing duties depend on how you are classified. The main categories are:
- Financial Counterparty (FC): banks, investment firms, fund managers, insurers and similar regulated entities.
- Non-Financial Counterparty above the clearing threshold (NFC+): non-financial firms whose derivatives activity exceeds the thresholds.
- Non-Financial Counterparty below the threshold (NFC-): non-financial firms below the thresholds, with lighter obligations.
- Small Financial Counterparty (SFC): smaller financial firms that fall under the relevant threshold.
Getting your classification right matters, because it drives what you must report and clear.
What Changed Under EMIR Refit?
The headline changes cluster around data, format and identifiers. Here is the shape of it at a glance.
| Area | Before Refit | Under EMIR Refit |
| Reportable fields | 129 | 203 |
| Reporting format | CSV | ISO 20022 XML |
| Product identifier | Inconsistent (ISIN, CFI, other) | UPI for OTC, ISIN for venue-traded |
| Reconcilable fields | 53 | Around 149 |
More Reportable Fields (129 to 203)
The number of reportable fields rose from 129 to 203, with 89 fields added and 15 withdrawn. Reconcilable fields jumped from 53 to roughly 149. More fields and far more reconciliation points mean a higher chance of mismatches, so reconciliation and data quality moved to the centre of compliance.
A New Format: ISO 20022 XML
Reporting moved from CSV to the ISO 20022 XML standard. This aligns derivatives reporting with the global messaging standard used across modern financial infrastructure. It is not a cosmetic change: it demands deeper alignment between front, middle and back office systems and, for many firms, new tooling to generate and validate reports.
New Identifiers: UPI, UTI and ISIN
Refit tightened how trades and products are identified, and this is where standardised codes do the heavy lifting.
The Unique Product Identifier (UPI) is now required for OTC derivatives, issued by the Derivatives Service Bureau. For derivatives traded on a venue, an ISIN is used instead. The Unique Transaction Identifier (UTI) follows a stricter generation and sharing logic so both sides can report consistently and on time.
Alongside these, the Legal Entity Identifier remains the code that identifies the counterparties themselves, which is the part many firms underestimate.
New Fields and Action Types (ERR, Revive, Margin and Collateral)
Refit also introduced structural additions. A new field, the Entity Responsible for Reporting (ERR), identifies the legal entity responsible for the report on OTC derivatives. A new action type, Revive, lets firms re-open a derivative at trade or position level. Margin and collateral data was separated into its own table, and valuation and margin reporting became more demanding, including daily end-of-day updates in the cases the rules specify.
How to Prepare for EMIR Refit Compliance
The Refit regime rewards firms that treat reporting as an ongoing process rather than a one-off project. A few priorities stand out.
Run a Gap Analysis and Test Early
Start with a gap analysis of your trade reporting against the new fields, format and validation rules, then test in a sandbox before relying on live reports. Firms that ran pre and post go-live dry runs had far smoother transitions. Building this into your wider financial compliance routine keeps it from slipping.
Keep Your LEIs Active and Valid
Make LEI renewal part of your reporting calendar, for your own entity and, where relevant, for the entities you report on behalf of. An expired code is one of the most avoidable causes of a failed report, and confirming whether each entity needs an LEI number in the first place removes nasty surprises later.
Handling Errors, Omissions and FCA Notifications
Firms must notify the FCA of material errors and omissions in their reporting, judged on the scale and significance of the issue. The FCA can impose penalties without a fixed maximum, and it has fined firms more than £34 million for reporting failures in the past, so robust controls and a clear remediation process are worth the effort. The same discipline applies across your other reporting duties, including FCA transaction reporting.
Why Your LEI Matters More Than Ever Under EMIR Refit
EMIR reports use the Legal Entity Identifier to identify legal-entity counterparties and certain other relevant entities. A legal-entity counterparty needs one, and so do the report submitting entity and the entity responsible for reporting, which is exactly where delegated reporting comes in.
The risk most firms miss is renewal. An LEI has to be renewed every year, and its reference data must be current when you report the conclusion or modification of a derivative contract. An out-of-date LEI can create validation, reporting, or reconciliation problems, so it should be treated as a core reporting control issue. Keeping every LEI current with a timely LEI renewal is a basic part of staying compliant, not an afterthought.
It also pays to check your counterparties. Before you trade, a quick LEI search confirms the other side holds a valid, active code. If your own entity still needs one, the documents required for LEI registration are modest and the process is quick.
Frequently Asked Questions
When did EMIR Refit go live?
The EU EMIR Refit went live on 29 April 2024, and the UK EMIR Refit followed on 30 September 2024. UK trades entered before that date had until 31 March 2025 to be brought into the new format.
Who has to report under UK EMIR Refit?
Derivative contracts are broadly reportable, but who actually submits the report depends on the counterparties. For OTC derivatives between a financial counterparty and a small non-financial counterparty (NFC-), the financial counterparty reports on behalf of both, unless the NFC- opts to report itself.
What are the main EMIR Refit changes?
The reportable fields rose from 129 to 203, reporting moved to the ISO 20022 XML format, and new identifiers (the UPI and a stricter UTI logic) were introduced, alongside new fields, a new Revive action type, and a separate table for margin and collateral.
Do I need an LEI for EMIR reporting?
Yes. EMIR reports use LEIs to identify legal-entity counterparties and certain other relevant entities, and the LEI reference data must be kept renewed. An out-of-date LEI can create validation, reporting, or reconciliation problems.
What is the difference between UK and EU EMIR Refit?
They are separate but broadly aligned regimes with different go-live dates and some differences in validation and fields. Firms reporting to both must report the same trade under two schemas, which adds operational complexity.
