A Global Wave of Rewrites Has Forced the Industry to Modernise
Author:
Michelle Zak
Managing Director
11 March 2026
The last two years have delivered the most intense cycle of transaction-reporting rewrites the industry has seen in a decade, effectively pushing firms toward scalable technological solutions.
APAC
- ASIC and MAS both implemented extensive OTC derivatives reporting rewrites.
- HKMA followed with its own update only weeks ago.
Europe & UK
- EMIR Refit went live in 2024, introducing ISO 20022, UPI, CPR workflows, new validations, and expanded fields.
- And now, the FCA’s Consultation Paper (21 November 2025) signals changes to UK MiFIR.
North America
- CFTC Rewrite phased in fully in 2024.
- CSA Rewrite arrived in 2025, following similar global-data-harmonisation themes.
Every rewrite has come with more fields, tougher validations, and more reconciliation constraints. Firms that previously relied on a patchwork of discrete platforms can no longer afford de-centralisation. This rings especially true of firms that cover multiple jurisdictions. Chances are that if you are a Swap Dealer on one regime, then you’ve got a global presence across regimes. This means multiple reporting obligations.
This global synchronisation, with regulators aligning around data standards like ISO 20022, UPI, and harmonised critical data elements, is a major catalyst for automation. Firms see a pathway to using one consistent technology framework across G10/G20 regimes, something that was almost impossible five years ago.
Larger institutions are now converging towards standardised data lakes and regulatory reporting engines that will pump out, at the very least, the Critical Data Elements that will fulfil the core requirements of most regimes, absent of course, MiFID in UK/Europe.
Leveraging technology is high on the list of transaction reporting agenda. This means leaving validations and detection of inaccuracies to the exports, and inhouse development focussed more on centralisation and standardisation.
Qomply has seen a notable increase in enquiries relating to our Quality Assurance and Accuracy solutions in Europe and UK, and in North America and APAC, more firms are signing onto our Reconciliation Solutions where there tends to be more demands from the regulators for the timely detection of breaks.
In 2026, expect to see a convergence to standardisation as the world pivots to technology and AI with specialised providers, such as Qomply, fully integrated in the workflow
Key Takeaways
- Regulatory rewrites are now global: APAC, Europe, the UK and North America have all moved through major transaction reporting reform cycles within a short period.
- Reporting complexity has materially increased: more fields, stricter validations and tighter reconciliation expectations are making fragmented operating models harder to sustain.
- Standardisation is becoming commercially viable: alignment around ISO 20022, UPI and harmonised data elements is making cross-jurisdiction reporting frameworks far more achievable.
- Multi-regime firms are under the most pressure: institutions with global footprints can no longer rely on separate local solutions for overlapping reporting obligations.
- Technology is shifting from helpful to essential: firms are converging on centralised data lakes, regulatory reporting engines and specialist providers to improve accuracy, reconciliation and scalability.