Now that Brexit is complete, EMIR firms registered in the EU need to comply with jurisdictional requirements established by the European Securities and Markets Authority (ESMA), while EMIR firms registered in the UK must comply with jurisdictional requirements established by individual trade repositories (TRs), which will provide trade, position, collateral, and valuation reports to the Financial Conduct Authority (FCA).
In anticipation of Brexit, most TRs created separate entities for the UK and EU. In fact, ESMA and FCA signed a MoU published on January 4, 2021 that lays out a plan for establishing TR equivalence in the future through registration or assessment.