ESMA seeks views on reporting under AIFMD 2 and the UCITS Directive

On 23 June 2025, ESMA published a discussion paper (the DP), "On the integrated collection of funds' data".

The DP was published alongside ESMA's call for evidence on streamlining financial transaction reporting across different reporting regimes, such as MiFIR, EMIR and SFTR. (See here for our summary of the Call for Evidence.)

Why has the DP been published?

The DP results from provisions in the AIFMD / UCITS Amending Directive. These mandate ESMA to submit a report to the European Commission by 16 April 2026, outlining the development of an integrated reporting system of supervisory data, with a focus on

• identifying areas of duplication with reporting in other sectors of the financial industry and
• improving data standardisation.

The DP seeks stakeholders' views which will help ESMA develop the recommendations that will form its Final Report.

ESMA notes that the Final Report will "place particular emphasis on the objective of reducing the reporting burden" for asset management firms by "outlining how enhanced data sharing among competent authorities, together with the effective application of the "report once" principle, can improve the efficiency of the reporting process".

Next steps

Responses must be made online under the relevant consultation link.

The consultation period closes on 21 September 2025.

ESMA expects to publish its Final Report with draft Level 2 RTS in April 2026.

What does the DP contain?

The DP sets out 24 questions focusing on reporting requirements arising out of AIFMD 2.0, the UCITS Directive and the Money Market Funds Regulation (MMFR).

Section 2 takes stock of the existing asset management reporting frameworks.

• this entails an in-depth review of periodic reporting obligations at the EU and Member State level, with the aim of identifying overlaps, redundancies, and inconsistencies across the frameworks.

• the DP also assesses best practice for data collection for retail funds (finding, for example, that some Member States align the reporting obligations for AIFs with those of UCITS so funds with similar risk profiles and / or investors are subject to the same regulatory treatment).

Section 3 assesses the overlaps and inconsistencies between reporting frameworks.

• evidence which ESMA has collected suggests that there could be more than 100 distinct asset-management reporting templates in use across the EU, varying by fund type and jurisdiction. As a result, there are "clear divergences" within supervisory reporting frameworks with respect to the reporting entities, the reporting frequency and the granularity of the reporting

• despite attempts to harmonise AIFMD reporting through guidelines, Q&As and technical reporting instructions, national differences persist - especially with regard to the additional reporting requirements in ESMA's Opinion on Collection of information for the effective monitoring of systemic risk under AIFMD. The DP notes that these requirements have not been endorsed by all Member States

• gaps exist between asset management reporting frameworks and these make supervision less effective

• ESMA's view is that a number of elements should be explored further as part of a move towards integrated reporting. These include

  • data semantics
  • reporting flows and data sharing
  • reporting formats and systems
  • granularity of data and data standardisation and
  • reporting frequency

  (For more information on these elements, see our summary of section 5, below.)

Section 4 presents a number of options to more fully integrate reporting obligations for fund managers under different regimes.

• ESMA regards the amendments to AIFMD and the UCITS Directive as a key opportunity to increase integration of supervisory reporting across the asset management sector with the alignment of reporting requirements under the two Directives serving as a major step toward a more consistent and harmonised reporting landscape at the EU level

• to this end, existing UCITS prudential reporting frameworks already implemented in some Member States could serve as a starting point for a future integrated reporting framework

• the DP stresses that the objective of the integrated template is not to introduce new data fields but to rationalise existing reporting requirements by focusing on elements that offer high added value

• the DP looks at a number of different options, each with its own pros and cons. These are

Option 1 - Multiple reporting obligations with reuse of data

this option would involve the creation of a coherent framework across multiple EU reporting regimes as a holistic view composed of multiple datasets. Under this system, data submitted once can serve multiple oversight purposes, making it possible to reuse data already reported in any EU reporting framework by all relevant competent authorities, at EU or at national level

Option 2 - Full integrated reporting framework

under this option, a new single EU-wide reporting structure would replace all existing EU and national-level reporting obligations under the AIFMD, UCITS Directive, MMFR, and statistical frameworks

Option 3 - Full integrated reporting framework including specific national reporting requirements

building on Option 2's modular approach (but adding an extra layer of flexibility for NCAs) under this option, the data model would accommodate national-specific reporting fields

this would allow authorities to collect information necessary for national supervisory and statistical priorities without disrupting the overall structure of the integrated framework - priority would, though, be given to reducing duplicative reporting requirements rather than expanding them

• ESMA also notes that establishing a more integrated reporting framework should not be limited to the asset management sector - a forward-looking strategy should assess how cross-sectoral alignment with other areas of the financial system could reduce duplication, improve data quality, and support more effective supervision - the DP considers, in particular, major reporting frameworks, such as EMIR, SFTR and MiFID/MiFIR which have significant overlap with the asset management field.

Section 5 details the main priorities for achieving further integration in the field of funds reporting. These include

• concentrating on elements with high added-value, i.e., prioritising data critical for achieving statistical and supervisory objectives, risk assessment, market surveillance, and enhancing investor protection

• the choice of data semantics - significant divergences, stemming from varying definitions, classifications, labels, and interpretations of the same data points across multiple regulatory frameworks, create inefficiencies, inconsistencies, leading to an increased reporting burden for fund managers.

• data granularity and use of master data -  AIFMD 2.0 will widen the scope of data, with a fund manager required to provide more detailed and comprehensive information to NCAs on, for example, the instruments in which it is trading, on markets of which it is a member or where it actively trades, and on the exposures and assets of the AIF/UCITS.

The DP sets out a number of options for streamlining supervisory reporting by eliminating duplicative reporting of exposures and asset breakdowns. These include

• security-by-security reporting (either full or partial)
• entities on which fund managers report information and
• share class reporting

• reporting frequency - the frequency of reporting under different regimes varies (annually, semi-annually, quarterly, monthly or daily) while, in some cases, the frequency depends on characteristics of the fund or its manager, based on the principle of proportionality.

Work on integrating reporting under AIFMD and UCITS provides an opportunity to reconsider the reporting frequencies.

One option could be to establish monthly reporting as the baseline frequency for all reporting regimes for funds - this might help streamline and integrate reporting process for market participants and facilitate the reuse of data by multiple authorities, for various purposes.

An alternative could be to maintain the current quarterly reporting frequency for supervisory reporting under AIFMD and UCITS.

Equally, ESMA ventures it could envisage daily frequency for some limited data points critical for supervision, as it is already the practice in some Member States (e.g., in relation to data on subscriptions and redemptions or NAV).