The announced go-live date creates challenges for companies which have reporting obligation to both EU and UK regulators, as there will be a five-month period during which the new EU REFIT solution will be in use, but clients should continue to manage legacy UK solution.

Similarly to EU REFIT, UK companies will have six months after the go-live date to update all outstanding derivatives into the REFIT format.

The UK FCA has adopted most of the EU EMIR REFIT regulation which has been published by European Securities and Markets Authority. The main changes introduced are broadly consistent, the number of new fields being introduced, UPI requirements, ISO 20022 XML format or the introduction of global logic structure for UTI.

Although the UK REFIT technical standards and validations are closely aligned with those of ESMA, they are not one-to-one. The FCA has introduced an additional field Execution Agent that allows firms to flag third-parties submitting on their behalf. The FCA also amended several validations as well as a number of fields include contain permitted values that differ slightly from those of ESMA.

Overall, the divergence between the EU and the UK regulation is minimal as of the go-live date. However, over time it is likely that these two schemes will diverge further.