Regulatory status checked: 10 August 2026.
Transaction reporting is a specialised operational discipline. Institutions must combine data from trading, customer, contract and collateral systems, apply regulatory logic, submit reports in the required format and process feedback from the receiving infrastructure.
This article was originally written before the revised EMIR reporting standards became applicable. The current framework and the direction of future reform are set out below.
The revised EMIR reporting regulatory and implementing technical standards have applied since 29 April 2024. Reporting under the framework uses common electronic and machine-readable formats based on ISO 20022 XML. Unique Product Identifiers are required for specified derivatives.
Firms also need to take account of ESMA’s reporting guidelines, validation rules, reconciliation tolerances and the technical schemas used by trade repositories. These requirements make data lineage, validation, error handling and control over reportable events central parts of the operating model.
The execution of a trade and the creation of its core data remain within the institution’s business and systems. Downstream activities may be supported by an internal shared service, a reporting vendor or another delegated arrangement. These activities can include enrichment, validation, formatting, transmission, feedback processing, correction workflows and management information.
In CMP’s project experience, financial institutions have increasingly evaluated vendor-supported models for these specialised downstream functions. The appropriate model still depends on the institution’s products, data architecture, control requirements, existing providers and ability to manage regulatory change.
Using a vendor does not remove the need for internal governance. Institutions still need clear ownership of source data, regulatory interpretation, oversight, exceptions and remediation.
In July 2026, ESMA published its final report on simplifying transaction reporting. ESMA recommends a staged approach towards a common, modular “report once” framework across MiFIR, EMIR and SFTR. The objective is to reduce duplicated and inconsistent reporting while allowing authorities to reuse data for their respective mandates.
This is a policy recommendation, not the current reporting model. Its implementation would require legislative changes, technical development and a phased transition. Institutions should therefore continue to comply with the existing frameworks while monitoring the development of the proposed integrated model.
A durable reporting setup should support traceable source data, documented regulatory decisions, version-controlled rules, automated validation where appropriate, effective exception handling and evidence that submitted reports are complete and accurate. These controls remain relevant whether reporting is performed internally or with external support.
Regulatory status checked: 10 August 2026. Regulation (EU) 2025/2075 requires in-scope transactions in transferable securities executed on EU trading venues
The financial-services advisory firm CMP is appointing Lene Hjortshøj as a new partner and opening an office in Aarhus to
