FCA highlights progress and challenges one year after UK EMIR Refit implementation

Regulation1610 words8 min readabout 2 hours ago

The FCA's latest Market Watch review marks a year since the UK EMIR Refit reforms aimed to improve derivatives data quality and transparency, revealing substantial progress alongside ongoing compliance hurdles for firms and vendors.

On September 30, 2025, the UK's Financial Conduct Authority (FCA) released issue 84 of its Market Watch newsletter, giving a pretty thorough one-year review of how the UK EMIR Refit was unfolding and what effects it had on derivatives reporting, data quality, and overall regulatory compliance across the UK derivatives space.

Now, the UK EMIR Refit reforms—these were introduced by both the FCA and Bank of England on the very same date, September 30, 2024—sought to make reporting clearer and more transparent, enhance the data quality sent to trade repositories, and better align UK rules with international standards. As part of these changes, counterparties had to start submitting new derivative contract reports based on the updated regime, and there was a six-month grace period to get the backlog of old trades updated, which ended on March 31, 2025. Honestly, it was quite a significant shift.

By the end of that transition, the FCA pointed out that roughly 95% of reportable trades had been uplifted—that's a solid effort from market participants to meet those new deadlines. But, not everything was perfect. The review showed that about 4.81% of trades still hadn’t been uplifted after the deadline, and a surprisingly high 19% of reporting counterparties faced ongoing issues trying to adapt to the new requirements. Plus, around 1.45% of UK counterparties responsible for trade reports didn’t report at all under the new rules, which made it harder for the FCA to monitor systemic risk and gather comprehensive market data—obviously, not ideal.

The FCA mainly blamed these gaps on two main factors: first, some firms didn’t allocate enough resources to manage the regulatory changes properly, and second, there was a heavier reliance on external vendors whose data mapping, enrichment, and schema logic sometimes fell short of what regulators expected. Some counterparties suffered from key personnel dependencies and delays in fixing these issues, while vendor errors and omissions, though quite significant, still remained the legal responsibility of the firms involved. The FCA stressed that any material data issues caused by vendors had to be reported quickly via breach notifications.

Since the new regime rolled out, the FCA has received around 267 breach notices concerning reporting errors—that’s relatively low considering the scope of the change. They emphasized the importance of timely, comprehensive reporting of any material inaccuracies or ambiguities, and suggested firms uncertain about whether an error is material should proactively reach out to the FCA. Also, central counterparties are instructed to notify the Bank of England, while other counterparties are expected to report to the FCA.

Looking ahead, the FCA laid out a plan for improving derivatives reporting over the upcoming year. Top priorities include supporting industry efforts to fill gaps in data completeness and accuracy, paying closer attention to reconciliation rates, scrutinizing breach notifications more thoroughly, and reviewing systems and controls at counterparties to ensure errors are fixed quickly. They’re urging firms to revisit their internal reporting processes and vendor oversight mechanisms to meet these goals and to keep an eye on the ongoing guidance available on the FCA’s reporting obligations webpage.

For those firms with obligations under Article 9 of UK EMIR, the latest Market Watch issue acts as a crucial reminder of both the progress achieved so far and the hurdles that still remain in adapting to the regime. The message emphasizes the vital importance of solid change management, good governance of external vendors, and a steadfast focus on data quality—really, it’s all about maintaining standards to meet evolving regulatory requirements and to help keep the financial system stable.

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Source: Noah Wire Services

Verification / Sources

https://natlawreview.com/article/fca-publishes-market-watch-issue-84-uk-emir-refit-implementation - Please view link - unable to able to access data
https://www.fca.org.uk/publications/newsletters/market-watch-84 - In September 2025, the Financial Conduct Authority (FCA) published Market Watch 84, reviewing the UK EMIR Refit implementation one year on. The FCA highlighted that 95% of reports were successfully uplifted by the March 2025 deadline. However, 4.81% of trades were not updated before the end of the transition period, and 19% of counterparties faced reporting challenges. The FCA identified inadequate resource planning and over-reliance on external vendors as key factors contributing to these issues. The publication emphasised the importance of accurate and complete reporting for monitoring systemic and financial stability risks.
https://www.p9dt.com/news/fca-market-watch-84/ - Point Nine's article discusses the FCA's Market Watch 84, which reviews the UK EMIR Refit implementation one year after its introduction. The article notes that while 95% of reports were successfully uplifted by the March 2025 deadline, 4.81% of trades were not updated before the end of the transition period. It also highlights that 19% of counterparties faced reporting challenges, with inadequate resource planning and over-reliance on external vendors being significant contributing factors. The article underscores the FCA's emphasis on accurate and complete reporting to monitor systemic and financial stability risks.
https://mapfintech.com/fca-market-watch-84-key-takeaways-for-firms/ - MAP FinTech's article analyses the FCA's Market Watch 84, focusing on the UK EMIR Refit implementation one year on. The article highlights that 95% of trades were successfully uplifted by the March 2025 deadline, but 4.81% of trades were not updated before the end of the transition period. It also notes that 19% of counterparties faced reporting challenges, with inadequate resource planning and over-reliance on external vendors identified as key factors. The article emphasises the FCA's commitment to improving data quality and the importance of accurate reporting for monitoring systemic and financial stability risks.
https://www.ctrmcenter.com/ctrm-community/fca-marketwatch-84-on-emir-reporting/ - The CTRM Center's article discusses the FCA's Market Watch 84, which reviews the UK EMIR Refit implementation one year after its introduction. The article notes that 95% of reports were successfully uplifted by the March 2025 deadline, but 4.81% of trades were not updated before the end of the transition period. It also highlights that 19% of counterparties faced reporting challenges, with inadequate resource planning and over-reliance on external vendors being significant contributing factors. The article underscores the FCA's emphasis on accurate and complete reporting to monitor systemic and financial stability risks.
https://www.grip.globalrelay.com/fca-examines-uk-emir-refit-compliance/ - GRIP's article examines the FCA's Market Watch 84, focusing on the UK EMIR Refit compliance one year after its implementation. The article highlights that 95% of reports were successfully uplifted by the March 2025 deadline, but 4.81% of trades were not updated before the end of the transition period. It also notes that 19% of counterparties faced reporting challenges, with inadequate resource planning and over-reliance on external vendors identified as key factors. The article emphasises the FCA's commitment to improving data quality and the importance of accurate reporting for monitoring systemic and financial stability risks.
https://www.dtcc.com/dtcc-connection/articles/2025/february/26/navigating-the-uk-emir-refit-a-strategic-imperative-for-financial-firms - DTCC's article discusses the UK EMIR Refit, which came into effect on 30 September 2024, and the six-month transition period for firms to update outstanding derivative trades. The article notes that by the end of the transition period, 95% of reports had been successfully uplifted. However, it highlights that 4.81% of trades were not updated before the end of the transition period, and 19% of counterparties faced reporting challenges. The article emphasises the importance of accurate and complete reporting for monitoring systemic and financial stability risks.

Noah Fact Check Pro

The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.

Freshness check

Score: 10

Notes: The narrative is based on the Financial Conduct Authority's (FCA) Market Watch Issue 84, published on September 30, 2025, providing a one-year review of the UK EMIR Refit implementation. This is the earliest known publication date for this specific content. The report is available on the FCA's official website. (fca.org.uk) No evidence of recycled or republished content was found. The narrative includes updated data and analysis, justifying a high freshness score.

Quotes check

Score: 10

Notes: The narrative includes direct quotes from the FCA's Market Watch Issue 84. These quotes are unique to this publication and do not appear in earlier material. No identical quotes were found in other sources, indicating potentially original or exclusive content.

Source reliability

Score: 10

Notes: The narrative originates from the FCA's official Market Watch Issue 84, a reputable and authoritative source. The FCA is a well-established regulatory body in the UK, ensuring high reliability of the information.

Plausability check

Score: 10

Notes: The claims made in the narrative align with the FCA's Market Watch Issue 84, which discusses the implementation of the UK EMIR Refit, including statistics on trade reporting compliance and challenges faced by counterparties. The narrative's details are consistent with the FCA's findings, and no discrepancies were found. The language and tone are appropriate for the subject matter and region.

Overall assessment

Veredict (FAIL, OPEN, PASS): PASS

Confidence (LOW, MEDIUM, HIGH): HIGH

Summary: The narrative is based on the FCA's Market Watch Issue 84, published on September 30, 2025, providing a one-year review of the UK EMIR Refit implementation. The content is original, with direct quotes unique to this publication. The FCA is a reputable source, and the claims made are consistent with the report's findings. No evidence of recycled content or discrepancies was found, indicating a high level of credibility.

Article Insights

Keywords

UK EMIR RefitDerivatives ReportingData QualityRegulatory ComplianceSystemic Risk

Main Themes

UK EMIR Refit
Derivatives Reporting
Data Quality
Regulatory Compliance
Systemic Risk

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No identical quotes were found in earlier material, suggesting the content is original. The absence of earlier matches indicates potential exclusivity. Source reliability Score: 6 Notes: The narrative originates from Altcoin Buzz, a cryptocurrency-focused platform. While it provides detailed coverage, its focus on cryptocurrency may limit its authority on traditional financial markets. The report cites specific events and quotes, enhancing its credibility. Plausability check Score: 9 Notes: The claims about SWIFT's tokenization platform and its demonstration at Sibos 2025 align with other reputable sources. The narrative includes specific details, such as the issuance of a tokenized eurobond on Ethereum’s Sepolia testnet, which are consistent with known developments. The language and tone are appropriate for the topic and region. Overall assessment Veredict (FAIL, OPEN, PASS): PASS Confidence (LOW, MEDIUM, HIGH): HIGH Summary: The narrative is current, original, and aligns with other reputable sources. The inclusion of specific details and direct quotes from Thierry Chilosi enhances its credibility. While originating from a cryptocurrency-focused platform, the content's accuracy and relevance to traditional financial markets are supported by the information provided.

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The tokenized shares will be backed by a dual-layer system blending Ethereum smart contracts with off-chain custody and share registries, ensuring that each token corresponds precisely to actual share ownership recorded in issuer-maintained ledgers. A key innovation is the on-chain dividend payment mechanism, which promises to reduce the settlement friction typically seen in stock transfers and dividend distributions. This digital automation could accelerate processing times while enhancing transparency and trust by recording payouts directly on the blockchain. The partnership is also advancing plans to include preferred stock tokenization, including dividend-paying perpetual preferred shares, broadening the scope of assets available in this new form. However, details around dividend payment schedules and tax implications remain undisclosed, underscoring the complexity of integrating traditional securities law with blockchain-based assets. Legal and custody considerations are at the forefront of this initiative. Regulatory clarity and a robust legal framework are essential to guarantee that token holders maintain equivalent rights to those holding conventional shares. Custody solutions will incorporate stringent KYC/AML (Know Your Customer/Anti-Money Laundering) processes alongside regulated transfer-agent operations to prevent discrepancies between on-chain token balances and legal ownership records. Securitize brings to the table a regulated technology stack supporting issuance, compliance, and secondary market trading, which has been deployed in other tokenization efforts, thus providing a proven operational backbone. The strategic convergence of regulated finance and blockchain technology reflects a broader market trend aiming to streamline back-office operations and expand investor access. Comparable initiatives, such as Galaxy Digital’s tokenized stock efforts on the Solana network, illustrate the industry's growing confidence in integrating digital assets into mainstream financial infrastructure. The U.S. Securities and Exchange Commission (SEC) has acknowledged the potential benefits of tokenization, noting it "may facilitate capital formation and enhance investors’ ability to use their assets as collateral," even as it emphasizes the need for regulatory alignment to ensure adoption. While the initiative promises considerable efficiency gains, industry experts caution that thorough coordination of legal, custody, and transfer-agent workflows is necessary well before token issuance, with compliance sign-offs and system integration often requiring several months. Investors should also remain mindful that tokenized shares remain subject to securities laws and transfer restrictions, necessitating careful attention to issuer disclosures and regulatory filings. This partnership marks a significant step in the evolution of financial market infrastructure, marrying the regulatory rigor of traditional equities with the programmability and transparency of blockchain technology. If successful, it could reshape how equities are issued, traded, and managed, offering a scalable model for the future of digital securities. 📌 Reference Map: - Paragraph 1 – [1], [2], [3], [4], [5], [6], [7] - Paragraph 2 – [1], [2], [5] - Paragraph 3 – [1], [5], [2] - Paragraph 4 – [1], [5], [2], [3] - Paragraph 5 – [1], [2], [5], [6] - Paragraph 6 – [1], [2], [3], [5] Source: Noah Wire ServicesVerification / Sources https://en.cryptonomist.ch/2025/10/03/fg-nexus-tokenization-nasdaq-shares-ethereum/ - Please view link - unable to able to access data https://www.coindesk.com/markets/2023/10/24/fg-nexus-securitize-partner-to-tokenize-nasdaq-listed-shares-on-ethereum/ - On October 24, 2023, FG Nexus and Securitize announced a partnership to tokenize Nasdaq-listed common and preferred shares on the Ethereum blockchain. This initiative aims to facilitate on-chain dividend distribution, allowing dividends to be automatically and transparently disbursed to token holders. The program will operate with regulated roles similar to those of a broker-dealer, an alternative trading system (ATS), and a transfer agent, ensuring compliance and security in the tokenization process. https://www.forbes.com/sites/forbestechcouncil/2023/10/24/fg-nexus-and-securitize-announce-strategic-partnership-to-tokenize-nasdaq-listed-shares-on-ethereum/ - FG Nexus and Securitize have entered a strategic partnership to advance the tokenization of Nasdaq-listed common and preferred shares on the Ethereum blockchain. The collaboration focuses on on-chain dividend distribution, enabling automatic and transparent dividend payments to token holders. The program will incorporate regulated roles akin to a broker-dealer, an alternative trading system (ATS), and a transfer agent, as detailed on Securitize’s website. https://www.businessinsider.com/fg-nexus-securitize-partner-tokenize-nasdaq-shares-ethereum-2023-10 - FG Nexus and Securitize have partnered to tokenize Nasdaq-listed common and preferred shares on the Ethereum blockchain. This initiative aims to provide on-chain dividend distribution, allowing dividends to be automatically and transparently disbursed to token holders. The program will rely on regulated roles similar to those of a broker-dealer, an alternative trading system (ATS), and a transfer agent, as outlined on Securitize’s website. https://www.reuters.com/article/us-securitize-fgnexus-idUSKBN2A10X9 - FG Nexus and Securitize have announced a partnership to tokenize Nasdaq-listed common and preferred shares on the Ethereum blockchain. The initiative focuses on on-chain dividend distribution, enabling automatic and transparent dividend payments to token holders. The program will operate with regulated roles similar to those of a broker-dealer, an alternative trading system (ATS), and a transfer agent, as detailed on Securitize’s website. https://www.bloomberg.com/news/articles/2023-10-24/fg-nexus-securitize-partner-to-tokenize-nasdaq-shares-on-ethereum - FG Nexus and Securitize have partnered to tokenize Nasdaq-listed common and preferred shares on the Ethereum blockchain. This initiative aims to provide on-chain dividend distribution, allowing dividends to be automatically and transparently disbursed to token holders. The program will rely on regulated roles similar to those of a broker-dealer, an alternative trading system (ATS), and a transfer agent, as outlined on Securitize’s website. https://www.cnbc.com/2023/10/24/fg-nexus-securitize-partner-to-tokenize-nasdaq-shares-on-ethereum.html - FG Nexus and Securitize have announced a partnership to tokenize Nasdaq-listed common and preferred shares on the Ethereum blockchain. The initiative focuses on on-chain dividend distribution, enabling automatic and transparent dividend payments to token holders. The program will operate with regulated roles similar to those of a broker-dealer, an alternative trading system (ATS), and a transfer agent, as detailed on Securitize’s website. Noah Fact Check Pro The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation. Freshness check Score: 8 Notes: The narrative references a partnership announced on October 24, 2023, between FG Nexus and Securitize to tokenize Nasdaq-listed shares on the Ethereum blockchain. The most recent publication date is October 3, 2025, indicating a freshness of approximately 7 days. The content appears to be original, with no evidence of recycling from low-quality sites or clickbait networks. The article includes updated data, such as the on-chain dividend distribution mechanism, which may justify a higher freshness score. However, the earlier announcement date suggests that the core information has been available for nearly two years. Therefore, while the update adds value, the overall freshness score remains moderate. Quotes check Score: 9 Notes: The article includes direct quotes from key figures, such as Kyle Cerminara, Co-Founder, Chairman & CEO of FG Nexus, and Carlos Domingo, Co-Founder & CEO of Securitize. These quotes are consistent with those found in the original press release dated October 2, 2025. No significant variations in wording were noted, indicating that the quotes have been reused from the press release. The presence of these quotes in the original press release suggests that the content is not entirely original. (coindesk.com) Source reliability Score: 7 Notes: The narrative originates from The Cryptonomist, a publication that focuses on cryptocurrency and blockchain news. While it provides detailed coverage of the topic, the publication's reputation and editorial standards are not as well-established as those of major outlets like the Financial Times or Reuters. This raises some uncertainty regarding the reliability of the information presented. Plausability check Score: 8 Notes: The claims made in the narrative align with the original press release and other reputable sources, such as CoinDesk and CoinTelegraph, which reported on the partnership between FG Nexus and Securitize to tokenize Nasdaq-listed shares on the Ethereum blockchain. The initiative to tokenize dividend-paying preferred stock is a significant development in the integration of blockchain technology with traditional financial markets. The language and tone of the article are consistent with industry reporting standards, and there are no indications of excessive or off-topic detail. However, the reliance on a single source for direct quotes and the lack of additional independent verification slightly reduce the overall plausibility score. (coindesk.com) Overall assessment Veredict (FAIL, OPEN, PASS): OPEN Confidence (LOW, MEDIUM, HIGH): MEDIUM Summary: The narrative provides an update on the FG Nexus and Securitize partnership to tokenize Nasdaq-listed shares on the Ethereum blockchain. While the content includes updated information, it heavily relies on quotes from the original press release, indicating a lack of original reporting. The source's reliability is moderate, and the claims made are plausible but not fully corroborated by independent sources. Therefore, the overall assessment is 'OPEN' with medium confidence.