ESMA Proposes Simplifying Transaction Reporting

On 23 June 2025, the European Securities and Markets Authority (ESMA) issued a Call for Evidence (CfE) to gather feedback from market participants on creating a more streamlined and unified framework for financial transaction reporting. This initiative covers several key regulations, including:

• Markets in Financial Instruments Regulation (MiFIR)
• European Market Infrastructure Regulation (EMIR)
• Securities Financing Transactions Regulation (SFTR)
• Potentially other frameworks, such as REMIT and Solvency II.

The Background

The CfE aligns with the EU’s broader goal of reducing regulatory burdens while improving reporting efficiency. As part of the recent “MiFIR Review” (implemented through Regulation (EU) 2024/791), ESMA was tasked with exploring ways to integrate and simplify transaction reporting across MiFIR, EMIR, and SFTR by March 2028.

Currently, transaction reporting is one of the most expensive compliance obligations for firms, with industry costs estimated at €1–4 billion annually. The fragmented approach across different regulations has led to duplication, inconsistencies, and higher compliance costs. ESMA’s CfE aims to address these challenges and create a more efficient system.

What Is the Scope of the CfE?

The CfE invites feedback on several key issues raised by market participants, including:

• Frequent regulatory changes
• Overlapping reporting requirements
• Inconsistent definitions and terminology
• Challenges with transaction-level and position-level reporting
• Dual-sided and intragroup reporting
• Variations in reporting channels

ESMA is also seeking input on two potential simplification proposals:

1. Eliminating Duplications in Existing Frameworks. This could be done either by delineation:

   • by instrument. For example, MiFIR could cover exchange-traded derivatives (ETDs); and EMIR could cover over-the-counter (OTC) derivatives and related post-trade events; or
   • by event. For example, MiFIR could cover both ETD and OTC derivatives transaction reporting; EMIR could cover post-trade events; and SFTR could be integrated into MiFIR and EMIR.

2. Creating a Unified Reporting Template (a “report once” proposal). This could be done:

   • in a more limited capacity. All instruments currently in scope of MiFIR, EMIR, and SFTR could be combined into a single unified reporting template, with MiFIR expanded to include EMIR and SFTR requirements;
     or
   • in a more expanded scope. The above mentioned unified reporting template could also cover other overlapping frameworks such as REMIT and Solvency II.

Timeline and Next Steps

Stakeholders have until 19 September 2025 to submit their feedback. ESMA plans to publish a final report in early 2026, outlining the preferred approach based on responses received.

How Does This Relate to the MiFIR Review?

In a related press release ESMA has clarified that while the CfE is ongoing, it will not proceed (in the short term) with any changes to the existing MiFIR reporting rules (under RTS 22, RTS 24, and RTS 23) under the MiFIR Review. Instead, it has published final reports summarising the feedback it has received on these topics as part of the MiFIR Review:

• Final Report on RTS 22 (transaction data reporting under Article 26) and RTS 24 (order book data under Article 25)
• Final Report on RTS 23 (reference data under Article 27)

ESMA’s aim, by putting on hold further changes to those RTS, is to allow market participants to avoid implementation efforts costs in these areas in the short term. The rest of the MiFIR Review will proceed as expected.

Interaction with AIFMD and UCITS

Under recent changes to Alternative Investment Fund Managers Directive (AIFMD) and Undertakings for Collective Investment in Transferable Securities (UCITS) ESMA was similarly given a mandate to consider simplifying reporting for asset managers. Under that mandate, and at the same time as the above-mentioned CfE was published, ESMA published a discussion paper to address duplication and inconsistencies between asset management reporting under AIFMD and UCITS and other financial sector frameworks. For more information on that discussion paper, see our article here.

What Does This Mean for You?

ESMA’s CfE is a key opportunity for firms to influence the future of transaction reporting in the EU. A unified and simplified approach could reduce costs, improve data quality, and enhance regulatory oversight. With the consultation deadline approaching in September, firms are encouraged to collaborate with their trade associations to ensure their views are represented and to help shape meaningful reforms.

If you have any questions, please reach out to your usual Simmons & Simmons contact or any member of our team.