EMIR Reporting is getting a change, the Financial Conduct Authority (FCA) has confirmed. From 26 January 2026, the Execution Agent field will move from optional to conditional under the revised EMIR Technical Standards.
This change is outlined in Handbook Notice No. 132 and reflected in the updated EMIR validation rules and XML schema. For firms reporting under EMIR, it introduces a new obligation that will affect both transaction and margin reporting.
EMIR Reporting: What is the Execution Agent?
The Execution Agent is the party that executes a trade on behalf of another counterparty. While this field has existed for some time, it has only been completed on a voluntary basis.
By making it conditional, the FCA aims to improve the quality and consistency of reported data across trade repositories. This additional transparency will also give regulators greater clarity over how transactions are executed and by whom.
The change applies to:
- Table 1 – transaction reporting
- Table 3 – margin reporting
Any counterparty that uses a broker or other third party to execute trades will need to ensure they can capture and report the Legal Entity Identifier (LEI) of that execution agent accurately and in a timely manner.
Why Is the Change Being Introduced?
The FCA has been clear that enhancing data quality is a priority. Making the Execution Agent field conditional ensures that the involvement of intermediaries is visible in the transaction report.
Earlier in 2025, the FCA consulted on this change as part of its Quarterly Consultation CP25/16, and industry participants, including ISDA, broadly supported the proposal.
The regulator has responded to feedback from firms that highlighted operational challenges. The implementation date has been moved from December 2025 to January 2026 to allow more time for preparation. This adjustment also avoids overlap with the Reconciliation Phase 2 go-live in April 2026.
Is There Enough Time to Prepare?
Although January 2026 may feel distant, it comes alongside a number of other regulatory updates planned for that year. Firms should act now to avoid operational pressures as the deadline approaches.
The change is not expected to be complex, but it will require firms to ensure:
- The ability to capture LEIs of execution agents
- System changes to populate the field automatically
- Procedures to validate the accuracy of data reported
Starting early will minimise risk, particularly for firms that rely on multiple brokers or third parties.
How Reg-X Can Help
At Reg-X, we work with financial institutions to simplify regulatory reporting under EMIR and other frameworks. Our middleware solution is designed to capture, map, and populate reporting fields directly from transaction data, including conditional fields such as the Execution Agent.
With decades of combined industry experience, our team understands the operational challenges firms face when new reporting requirements are introduced. We support our clients by:
- Updating reporting logic to reflect new validation rules and schema changes
- Ensuring data fields are populated correctly and consistently
- Providing advisory services for firms that need clarity on the latest FCA requirements
Whether you manage your own reporting or use a delegated service, Reg-X can help you prepare for the new Execution Agent obligation with confidence.
Preparing for 2026 and Beyond
The change to the Execution Agent field is part of a wider set of updates scheduled for 2026. As regulators increase their focus on transparency and accuracy, firms need to ensure their reporting processes are robust, flexible, and future-proof.
At Reg-X, we believe regulatory change should not be a burden. With the right systems and expertise, firms can turn compliance into a reliable, well-controlled process.
