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ARTICLE · 31 AUGUST 2025

FCA Makes the ‘Execution Agent' Field Conditional under EMIR

These new validation rules will take effect from 26 January 2026 (Implementation Date).

United KingdomFinance and Banking

The UK Financial Conduct Authority (FCA) has introduced changes making the field 'Execution Agent' a conditional field to report under EMIR. The new requirements transaction reports are reflected in the EMIR Technical Standards on reporting through Handbook Notice No 132 and updated EMIR validation rules and XML schema. These new validation rules will take effect from 26 January 2026 (Implementation Date).

What is the 'Execution Agent' and what exactly are the changes?

The 'Execution Agent' field identifies the party that executes a trade on another's behalf. Given this is currently an optional field and firms have been voluntarily completing this field, making it conditional will improve data quality and consistency amongst the trade repositories and transparency of executed transactions. The changes apply to Table 3 for margin reporting and Table 1 for transaction reporting.

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