On 31 October 2025, the Bank of England (BoE) and Financial Conduct Authority (FCA) (the authorities) published final versions of additional Q&As in relation to derivative reporting requirements under the UK European Market Infrastructure Regulation (UK EMIR) having consulted on draft Q&As in August 2025.
Background
Key changes
- Q&A 4.14 – when is it acceptable to report with a technical ISIN?: include an additional scenario alongside those originally specified in the draft Q&As, and an additional technical ISIN was also created for use in that scenario.
- Q&A 11.7 – how should a ‘FX swap’ be reported?: provide further clarification regarding FX swap types and include a table illustrating reporting expectations for ‘FX swaps’.

