Your EMIR Obligation Isn’t Going Away. Your Manual Process Should.
If your monthly close still involves exporting trade data into a spreadsheet, building dual submission files for the EU and UK Trade Repositories and hoping nothing comes back rejected, you’re in good company. It’s how most corporate treasury teams handle EMIR reporting today. But the regulatory environment has gotten more demanding and the margin for error keeps narrowing.
There’s a better way to manage it. AtlasFX EMIR Reporting is here.
What EMIR reporting actually requires
If your group has entities under both regimes (and most multinationals do) that means two separate reporting obligations, two sets of technical standards and two distinct submission pipelines running in parallel.
Since Refit, field requirements have expanded significantly: more than 203 data fields per trade, formatted to ISO 20022 XML specification. The EU and UK regimes have also diverged. The Bank of England amended UK technical standards in January 2026, adding another layer of complexity to manage. It’s a compliance surface that keeps growing.
Where the burden shows up
For most treasury teams, EMIR reporting is still a manual cycle: trade data extracted from one system, formatted to spec, reviewed for errors and submitted twice, once for ESMA and once for the FCA. The process is time-consuming, and the risk is structural. Without pre-submission validation, errors only surface when the Trade Repository rejects the file. By then you’re into remediation.
This is one of the clearer treasury pain points in FX risk management: teams already know where the gaps sit in their FX workflow long before a regulator finds them.
Your bank isn’t covering this
Many treasury teams assume their bank’s delegated reporting covers their EMIR obligations. It doesn’t, at least not entirely. Banks report the bilateral trades executed directly with them. Your internal intercompany FX trades between group entities are a separate compliance surface and one your bank isn’t reporting. In most corporate groups, those trades are still handled manually, often in the same spreadsheets that already strain under broader FX risk management workflows.
The oversight gap
Once a file is submitted, most teams have limited visibility into what was actually filed or whether it passed validation. That matters more now than it did a year ago. ESMA publishes a data quality dashboard that tracks error rates at the entity level and shares flagged records directly with national regulators. The legal obligation for accuracy sits with your entity regardless of who submits. If a regulator asks questions, you need a clear answer.
Who is responsible if something goes wrong?
Under EMIR, the Entity Responsible for Reporting retains full legal accountability for the accuracy, completeness and timeliness of every filing regardless of whether a third party service submits on their behalf. Automation doesn’t transfer the obligation. What it does is give your team the tools to meet it with far less effort and the audit trail to demonstrate oversight if a regulator ever asks. No FX surprises starts with always knowing what was submitted and why.
Introducing AtlasFX EMIR Reporting
AtlasFX is a built-by-practitioners FX risk management platform for corporate treasury teams, covering everything from balance sheet hedging to cash flow hedging to intercompany FX, and now EMIR Reporting. As an end-to-end FX risk management platform, AtlasFX integrates EMIR Reporting directly into the existing system so trades flow automatically into the reporting cycle without any manual handoff.
Trades are captured, enriched with all required EU and UK EMIR fields and validated for data quality before submission. Exceptions are flagged in a client dashboard for review rather than discovered in a rejection notice afterwards. Correct ISO 20022 XML files are then generated and submitted to the appropriate Trade Repository for each jurisdiction simultaneously.
Key benefits:
- Minimal manual effort: automated trade capture, enrichment and dual jurisdiction submission eliminate manual data extraction and spreadsheet formatting, leaving your team with a quick review and approval step before filing
- Pre-submission data quality validation: every trade validated against EMIR rules before the file reaches the Trade Repository, reducing TR rejections and post-submission remediation
- Dual jurisdiction coverage: EU EMIR (ESMA) and UK EMIR (FCA) handled simultaneously from a single automated process, maintained for regulatory changes including the January 2026 UK amendment
- Full client oversight: a real time exception management dashboard and complete audit trail for every filing, so you always know what was submitted, when and whether it passed
Configurable to your organization’s entity structure and reporting calendar, AtlasFX EMIR Reporting is one more example of how customizable FX risk management solutions are replacing one-size-fits-all compliance processes.
The obligation stays with your company. AtlasFX EMIR Reporting gives you the tools to meet it without manual effort.
See it in action
AtlasFX EMIR Reporting is live and available now. If you’re currently managing EMIR reporting manually, or evaluating whether. AtlasFX is the right fit for your treasury operations more broadly, we’d welcome the conversation.
Contact AtlasFX to book a discovery call, or explore our FX risk management resources to see how other treasury teams are modernizing their FX program.
