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ESMA call for evidence on comprehensive approach for the simplification of financial transaction reporting

19 September 2025
  • Before designing any new proposal, the rationale and objectives for requesting the current extensive amount of data should be thoroughly assessed
  • Particularly, if a new reporting regime is proposed, it should be final and stable as changes are the main cost driver
  • The reporting responsibilities assigned to the various parties should be always clear, ideally based on the principle that ETD-reporting responsibilities sit with trading venues/CCPs/clearing banks and OTC-reporting responsibilities sit with investment firms. Wherefore noninvestment firms would only be responsible for bilateral transactions with another one (possibly in a well-defined one-sided manner)
  • In keeping with these considerations, the preference goes to Option 1a
  • Option 1b should be discarded as it would risk requiring new obligations and costly system adjustments for noninvestment firms under MiFIR
  • Though having a larger harmonization potential than Option 1a in the long term, Option 2a is riskier as it would bring more complexity while also undermining the clarity of reporting responsibilities
  • Option 2b should also be discarded as it carries the same drawbacks of Option 2a, without in turn harmonization potential as it would disrupt the clear scope distinction between financial regulation and REMIT (which should be maintained)
  • Reporting timelines should also be reviewed, for example eliminating daily reporting, to support market-surveillance needs without overburdening market participants

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