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ARTICLE · 01 OCTOBER 2025

EMIR – Unique Client IDs / Duplicate Counterparty 2 Identifiers

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Why does EMIIR require a Unique Client ID? What is EMIR's approach to internal client identifiers? How does this issue arise? When should the UCI be created?

United KingdomFinance and Banking
Quinn Perrott
Quinn Perrott
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Since the updates to UK & EU EMIR in 2024, one of the main recurring issues in CFD reporting is in relation to how firms create and use client identifiers for 'Counterparty 2' clients. The confusion seems to be from mixing platform client login IDs with the client code required by EMIR. Also, using different local IDs for the same person across trading platforms adds to this problem.

Why does EMIIR require a 'Unique' Client Code or Identifier?

EMIR requires that counterparties that are legal entities have a legal entity identifier (LEI). For those counterparties that are natural persons and not eligible for an LEI, firms must generate a client code in line with the EMIR Implementing Technical Standards (ITS). The client code must consist of the reporting counterparty's LEI with an internal identifier as allocated by the firm. The result should be that the same client is always reported under a single identifier, despite the platform, account or login used. This

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