Quick Summary

  • EU EMIR REFIT Phase 2 Reconciliation went live on April 27, 2026 - 61 new fields are now reconciled, bringing the total to 148 reconcilable fields

  • UK EMIR REFIT Phase 2 Reconciliation goes live on September 28, 2026

  • The FCA has published an updated validation specification amending Trade Repository (TR) reconciliation requirements

  • Separating material breaks from reconciliation noise is now the defining challenge for compliance teams

  • The balance has flipped - reconciliation is now the rule, not the exception.

What Is EMIR REFIT Phase 2 Reconciliation?

EU EMIR REFIT Phase 2 Reconciliation is now live, and the impacts will be felt most sharply in the reconciliation reports streaming out from Trade Repositories. Valuations, Baskets, Schedules, and more are now fully reconcilable - and separating the new signals from a significant volume of new noise will require a step change in how firms approach reconciliation review.

To understand which reconciliation breaks are truly material (pointing to incorrect reporting) versus which are noisy (pointing to approach-level inconsistency rather than substantive error), it helps to go back to basics on inter-TR reconciliation.

Why Does Inter-TR Reconciliation Exist?

Reconciliation inside and between Trade Repositories is an EMIR- and SFTR-only concept. The goal is to improve data quality - as referenced directly in EMIR REFIT: "The insufficient quality and transparency of data … makes it difficult for entities … to use them to monitor derivatives markets and prevents [them] from identifying financial stability risks."

With 61 new fields now in scope - many covering traditionally internal concepts - there is a meaningful risk that reconciliation surfaces differences where firms are tracking the same information in a marginally different way. These are correct, but different, approaches to reporting the same economic reality.

Firms should classify these differences separately from genuine breaks, where a contract term has been reported with a substantively different value. In some cases, tolerances will help bridge the gap - but you cannot round an Index Name to the nearest whole number.

What New Fields Are Now Reconciled Under EMIR REFIT Phase 2?

61 additional fields are added to the reconciliation scope, bringing the total to 148 reconcilable fields:

  • Prior UTI and Subsequent Position UTI

  • Crypto Asset Derivative Indicator

  • Indicator and Name of the Underlying Index

  • Custom Basket Code and Identifier of the basket’s constituents

  • Settlement Currency 1 and 2

  • Valuation Amount, Currency, and Method, and Delta

  • Price Schedule - Price, Effective Date, and End Date

  • Package Transaction Price, Price Currency, Spread, and Spread Currency

  • Other Payments fields - Type, Amount, Currency, Payer, and Receiver

  • Spread and Spread Currency of Leg 1 and 2

  • Exchange Rate 1, Forward Exchange Rate, and Exchange Rate Basis

  • Base Product, Sub Product, and Further Sub-Product

  • Energy Delivery Attributes

    • Delivery Point or Zone

    • Interconnection Point

    • Load Type

    • Delivery Interval Start Time

    • Delivery Interval End Time

    • Delivery Start Date

    • Delivery End Date

    • Duration

    • Days of the week

    • Delivery capacity

    • Quantity Unit

    • Price/time interval quantity

    • Currency of the price/time interval quantity

  • Strike Price and Strike Price Currency

  • Strike Price Schedule - Price, Effective Date, and End Date

  • Option Premium Amount, Currency, and Payment Date

  • CDS Index Series and Version

  • CDS Index Tranche Attachment and Detachment Points

Where Are Non-Material Reconciliation Breaks Most Likely?

The single biggest source of non-material breaks is likely to be the newly reconciled free text field: Name of the Underlying Index. Officially, the correct value has been defined as "the full name of the index as assigned by the index provider" since July 2018 per the RTS 2 Q&A - but many firms have not prioritized the manual review needed to perfect this field.

String comparison is binary: it matches or it doesn't. Getting to 100% alignment on a breaking free text field will be a slow, iterative process between counterparties. Each break requires review and an agreed action for one party to amend their reporting - with potential knock-on effects for any other trades referencing the same index with other counterparties.

The real risk may not be the values that are breaking, but the ones that are not. If a reconciliation with one counterparty surfaces a marginally incorrect index name and you decide to correct it, how do you handle the trades with another counterparty that are currently matched against that same incorrect value?

The short-term answer requires a configurable system capable of setting fields dynamically based on conditions. The long-term answer points toward an authoritative naming source becoming increasingly valuable to reference.

This is one area where simplification has already appeared on the FCA's agenda: the Name of the Underlying Index field will not be reconciled under UK EMIR. That said, while the EU retains the requirement, this divergence will offer limited relief for firms operating across both jurisdictions.

What Is Best Practice for Material Reconciliation Breaks?

For many of the new fields, reconciliation - even when unwelcome - is not unproductive. When breaks point to genuine reporting issues, a structured multi-step process is needed:

  • Define the production reporting problem and its scope. The immediate priority is a targeted fix to stop the bleeding - a precise correction to halt ongoing misreporting.

  • Identify and remediate the open error population. Determine whether every historical version requires correction or only the latest. Remediation must be carefully choreographed with ongoing reporting to avoid compounding the issue.

  • Address the closed error population. Depending on your systems and reporting capabilities, this will range from straightforward to near impossible. Understand your constraints before committing to a correction timeline.

  • Identify upstream causes, notify counterparties and regulators, and formulate a correction plan. If your vendor or system cannot support parallel remediation workflows, or places limits on data processing volumes, your plan must be built around those constraints - not despite them.

How Does the UK Differ from the EU on Phase 2 Reconciliation?

UK EMIR REFIT Phase 2 Reconciliation goes live on September 28, 2026 - two years after the UK REFIT reporting obligation commenced on September 30, 2024. The FCA has published an updated validation specification that amends TR reconciliation requirements for UK reporting entities.

The most notable UK divergence is the exclusion of the Name of the Underlying Index from UK reconcilable fields. For multi-jurisdictional firms reporting under both regimes, this means maintaining parallel approaches to a field that can generate high break volumes in the EU - and must be managed carefully to avoid creating new mismatches when correcting EU breaks.

Beyond this, UK Phase 2 reconciliation closely mirrors the EU's approach in terms of scope and structure.

How KOR Supports EMIR Reconciliation and Remediation

At KOR, we hear about remediation - and the potential for remediation - as a primary requirement from many of the firms we speak with. Producing a system that can scale to meet end user requirements from one day to the next has driven our design from day one.

Whether you are working through EU Phase 2 go-live impacts now, preparing for UK go-live in September 2026, or managing a backlog of open errors that have just become visible through the expanded reconciliation scope, KOR is built to support you at every stage.

Reach out to talk EMIR, Reconciliation, Remediation, or anything else today.

KOR is a regulatory reporting technology firm specializing in trade reporting, reconciliation, and remediation across EMIR, SFTR, and global trade and transaction reporting regulations.