EMIR Refit: Lessons learned from the EU and UK implementations
Abstract
The European Market Infrastructure Regulation (EMIR) was introduced to enhance the transparency and stability of over-the-counter (OTC) derivatives markets in the wake of the 2008 financial crisis. Since its implementation in 2014, EMIR has undergone several updates, including the 2024 EMIR Refit, aimed at simplifying reporting requirements, reducing compliance burdens and ensuring better market transparency. This paper explores lessons learned from the implementation of EMIR Refit in both the European Union (EU) and the UK, highlighting key changes in regulatory requirements, such as simplified reporting, harmonised data standards and intragroup exemptions. Despite the goals of simplifying compliance, firms continue to face significant challenges in adapting to the 2024 Refit, including issues related to system upgrades, ambiguous regulatory language and data reconciliation. The paper discusses common hurdles such as inconsistent implementations, inadequate project planning and the complexity of transitioning to new data standards such as ISO 20022.1 It also examines the importance of clear governance, effective testing and the need for cross-functional collaboration within firms to meet regulatory expectations. The findings emphasise the necessity of early preparation, robust technical frameworks and continuous regulatory engagement to navigate the evolving regulatory landscape. Ultimately, the paper offers practical recommendations for firms to improve compliance, operational efficiency and adaptability in future regulatory transitions, including the development of an implementation blueprint for ongoing regulatory evolution. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.
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Author's Biography
Andrew Leonard is Barclays’ multi-entity Compliance subject matter expert lead for Financial Conduct Authority (FCA) regulatory reporting across transaction reporting (RTS 22/23), European Market Infrastructure Regulation, post-trade transparency (RTS 1 and 2), Securities Financing Transaction Regulation and additional regulatory areas, working closely with the Americas and Asia Pacific regions to ensure consistency. He provides advisory support on regulatory and compliance matters to global investment banking operations and front-line business to ensure compliance with regulatory obligations and adherence to conduct, policies and standards. Prior to joining Barclays, Andrew spent nearly five years at the FCA in Secondary Markets’ Markets Reporting Team, leading oversight of firms in their reporting to the FCA and working closely with policy, supervision and enforcement areas within the FCA. Additionally, he brings significant investment banking experience, having worked in sales trading and trading at buy-side and sellside investment firms for over 15 years prior to his time at the FCA.
