Market Watch 84, published by the FCA in September 2025, offers a detailed review of how firms have adapted to the UK EMIR Refit one year on. The newsletter examines the progress made, challenges still faced, and supervisory priorities for the year ahead. It also provides lessons that extend beyond EMIR, offering insights for firms across the reporting landscape.
This article explores the five key insights from Market Watch 84 and how firms can apply them to strengthen compliance frameworks.
1. Market Watch 84 confirms data quality is paramount
A central theme in Market Watch 84 is data quality. The FCA notes that the UK EMIR Refit was designed to raise the standard of transaction data and to align with global reporting practices. High-quality data has already supported monitoring of systemic risks, including exposure to critical benchmarks during volatile conditions.
For firms, the message is clear: data accuracy and completeness are non-negotiable. Regulators expect firms to validate submissions, monitor reconciliation breaks and resolve discrepancies quickly. Poor quality data not only undermines compliance but also damages confidence in markets.
2. Change management challenges in Market Watch 84
The FCA highlights that around 19 per cent of firms experienced difficulties in the transition to EMIR Refit. According to Market Watch 84, weaknesses included poor governance, inadequate resource planning, and over-reliance on key individuals.
The newsletter stresses that change management must be a structured, well-resourced programme. Firms need robust governance frameworks, clear documentation, and contingency planning to ensure smooth transitions. Lessons from the EMIR Refit apply broadly to all regulatory change projects, not just derivatives reporting.
3. Market Watch 84 highlights vendor oversight risks
A third key takeaway from Market Watch 84 relates to vendor oversight. While many firms depend on third-party providers for regulatory reporting, the FCA highlighted recurring issues such as mapping errors and limited vendor capacity.
At Reg-X, we have consistently been at the forefront of enhancing regulatory reporting data quality. Our clients frequently recognise us for our razor-sharp focus and proven ability to improve accuracy in this space.
The FCA’s message is unambiguous: firms remain fully accountable for the accuracy of their reporting. Outsourcing does not transfer responsibility. To strengthen oversight, firms should establish clear service-level agreements, actively monitor vendor performance, and validate data prior to submission. Maintaining strong in-house expertise is equally vital to effectively identify and challenge vendor errors.
4. Underuse of Error Notifications – Market Watch 84
Since go-live, the FCA has received just 267 error or omission notifications. Market Watch 84 highlights this as being lower than expected, suggesting that firms may not be consistently reporting material breaches.
The FCA’s guidance is clear: firms should err on the side of caution. It is better to be transparent in reporting errors than risk under-reporting. Any decision to treat issues as immaterial must be well-documented and defensible. To avoid supervisory repercussions, firms need clear escalation frameworks that are applied consistently.
Reg-X’s EnO Analytics solution supports firms in optimising processes, strengthening decision-making, and enhancing compliance with error and omission obligations.
5. Future supervisory focus in Market Watch 84
Looking ahead, Market Watch 84 sets out the supervisory priorities of the FCA and Bank of England. These include reconciliation rates, vendor oversight, and data quality monitoring. The message to firms is that supervisory intensity will increase, and preparation is essential.
Recommended actions include:
- Reviewing reconciliation processes and resolving breaks promptly
- Improving vendor oversight with stronger controls and monitoring
- Establishing transparent error notification processes
- Continuing investment in validation and data quality measures
By acting now, firms can meet expectations and avoid costly remediation.
How Reg-X can support firms
At Reg-X Innovations, we help firms adapt to regulatory change and improve the quality of their reporting. Our middleware automates data mapping and validation, identifies exceptions, and manages reconciliation breaks before submission. Our Assurance solutions, like Completeness reconciliation and Accuracy testing, offer robust controls for firms.
Drawing on combined industry expertise, we also offer consulting and outsourcing to support change management, vendor oversight, and data governance. The lessons from Market Watch 84 highlight that effective compliance requires strong systems, reliable processes, and expert guidance, areas where Reg-X delivers value.
Next steps
Market Watch 84 is an important reminder that compliance is not a one-off exercise but an ongoing process. Firms should carefully assess the FCA’s findings and apply them to their own frameworks. By prioritising data quality, strengthening governance, and improving vendor oversight, firms can prepare for heightened supervisory scrutiny.
At Reg-X, we will be releasing an in-depth analysis of Market Watch 84 in the coming weeks. This will provide further insights into the FCA’s findings and practical steps firms can take to strengthen reporting.
For further details, read the full FCA Market Watch 84 newsletter.
