On 23 June 2025, the European Securities and Markets Authority (ESMA) published a Call for Evidence on the simplification of financial transaction reporting. The Call for Evidence comes as part of a mandate provided to ESMA to assess the feasibility of more integration in transaction reporting and the streamlining of data flows to reduce duplicative or inconsistent requirements for transaction data reporting.

ESMA uses the Call for Evidence to identify major cost drivers stemming from regulatory reporting and how to best improve the overall framework.

Key issues

Section 3 of the Call for Evidence sets out the key issues related to multiple regulatory reporting regimes for duplicative or inconsistent requirements. Such issues include the overlapping obligations across different reporting regimes, such as the Markets in Financial Instruments Regulation (MiFIR), the European Markets Infrastructure Regulation (EMIR), and the Securities Financing Transaction Regulation (SFTR). In particular, the identified issues are:

  • Frequent regulatory changes and a lack of flexibility to enable a phased implementation.
  • Duplicative reporting of the same derivative instruments under MiFIR, EMIR and the Regulation on wholesale energy market integrity and transparency (REMIT).
  • Different terminology and definitions within different reporting regimes.
  • Requirements to report both transaction-level and position-level data under EMIR, SFTR, and MiFIR commodities position reporting.
  • Dual-sided reporting obligation under EMIR and SFTR.
  • Intragroup derivative reporting and related difficulties.
  • Reference data reporting duplications.
  • Different reporting channels across MiFIR, EMIR, SFTR and REMIT.
  • The duplication of IT systems and processes.

Different approaches

Section 4 of the Call for Evidence discusses a number of different approaches ESMA considers taking in its simplification efforts. All of the options it considers are based on four principles: preserving the information scope; decreasing the overlap to reduce burden; ensuring global alignment; and balancing cost and benefit.

ESMA suggests two different options that each exist of two sub-options. These are:

  • Option 1: Removal of duplication in the current frameworks. This option would directly eliminate duplication in the scope of the reporting requirements without directly changing the legal set up for the current reporting channels and data collection infrastructures. It would review the transaction reporting requirements in EMIR, MiFIR and SFTR.
    • Sub-option 1a proposes a delineation of reporting scope based on the type of trading of the instrument, splitting the reporting between exchange-traded derivatives (ETD) and over-the-counter (OTC) derivatives.
    • Sub-option 1b would, instead of sub-option 1a, delineate the reporting scope based on events. For example, MiFIR would cover both ETD and OTC transaction reporting while EMIR would retain all post-trade events. The SFTR would be integrated under MiFIR and EMIR.
  • Option 2: Implementation of the “report once” principle. This option could be considered as a second step that follows the first option. It involves the creation of a unified template for reporting information that is currently distributed across various regimes. ESMA also presents two sub-options:
    • Sub-option 2a would apply the “report once” principle in full to MiFIR, EMIR and SFTR.
    • Sub-option 2b would expand the “report once” principle to other regimes, such as REMIT, as well.

ESMA asks, among other things, for views on the options it presents, stakeholder preferences, and possible alternative options. In addition, it asks respondents for their views on the possible modification of reporting channels and flows, the advantages and disadvantages of transferring the reporting of on-venue transactions under MiFIR and EMIR to trading venues, and the enhancement of ESMA’s role as a data hub.

Section 5 of the Call for Evidence provides a high-level impact analysis of the effects of putting the options into practice.

RTS 22, 23 and 24

In addition to the Call for Evidence, ESMA announced that, for now, it will not propose changes to the existing reporting frameworks on transaction reports (RTS 22), order data (RTS 24) and reference data (RTS 23) under the MiFIR Review (ESMA consulted on amendments to RTS 22 and RTS 24 in October 2024, and on amendments to RTS 23 in May 2024). As the outcome of the Call for Evidence may impact its proposed amendments, it has paused the publication of final draft RTS and published final reports summarising the feedback it received from respondents to the consultations instead.

Next steps

ESMA invites stakeholders to provide feedback to the Call for Evidence by 19 September 2025.

Based on the feedback, ESMA will publish a final report by the beginning of 2026.