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ARTICLE · 18 JANUARY 2026

When Do Validations Kick In For Certain EMIR Refit Fields?

Reconciliation Phase II (Phase II) is to go live in April 2026 for EU EMIR and September 2026 for UK EMIR.

United KingdomFinance and Banking

Reconciliation Phase II (Phase II) is to go live in April 2026 for EU EMIR and September 2026 for UK EMIR. These dates are 2 years after the implementation dates for EMIR Refit for both jurisdictions.
Phase II brings with it:

  • 61 brand new fields which are to be added to the scope of both inter and intra TR reconciliation and also includes valuation updates; and
  • 4 new reconciliation statuses in Reconciliation and Trade State reports.

The EMIR Refit Validation Rules (EU) provide a 'Reconciliation Tolerance' column, specifying whether the item allows for any tolerance in terms of matching. For example, for item 25 (Delta), the reconciliation tolerance column provides 'yes', that there is tolerance where fields do not entirely match - this may also be subject to certain conditions. Of the 61 brand new fields, 39 have 'no' tolerance and therefore have to match exactly, with the remaining 22 allowing for some tolerance or flexibility. For more information

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