Amendments proposal to MIFIR’s Transaction Reporting requirements has been postponed by the European Commission following public consultation on the review of the RTS 22[1]. In the following article, we explore the latest developments in EU transaction and trade reporting regulation.
In October 2024, the European Securities and Markets Authority (ESMA) published a Consultation Paper proposing revisions to Regulatory Technical Standards (RTS) 22 under Article 26 of MiFIR. Key proposals included:
- Expanding reporting obligations to a broader range of derivative instruments
- Nearly doubling the number of data fields to be reported
- Transitioning from XML to JSON
- Aligning MiFIR reporting more closely with EMIR and SFTR frameworks
The introduction of additional fields may require firms technical implementation effort to ensure compliance with the revised framework, though the direct impact on data quality is to be seen. While the Consultation Paper looks at ways to enhance standardisation, certain proposals —such as moving from XML to JSON— could create some operational challenges and hinder effective alignment of MiFIR, EMIR, and SFTR, which may increase complexity and compliance costs for firms.
A Final Report from ESMA was initially expected by end of Q1 / early Q2 2025, with a full set of amendment proposals for the European Commission’s endorsement or rejection. However, in light of industry feedback and the EU’s broader push for regulatory simplification and burden reduction —as outlined in initiatives like A Competitive Compass for the EU[2] and A Simpler and Faster Europe[3]— ESMA took a different approach.
Instead of proposing amendments, ESMA issued a Call for Evidence in June 2025 to explore a more holistic and streamlined transaction reporting framework across multiple regulations[4].
A New Paradigm?
ESMA’s Call for Evidence highlights persistent challenges in the EU’s regulatory landscape, particularly the overlapping and inconsistent requirements across MiFIR, EMIR, and SFTR. It outlines two main simplification strategies, each with sub-options:
- Removal of duplications
- Differentiate based on instrument type (on-venue vs. OTC).
- Differentiate based on event type (transactions vs. post-trade events).
- Adoption of Report Once Principle
- Unified reporting across MiFIR, EMIR, and SFTR.
- Expanded scope to include other regulations (e.g., Solvency II, REMIT).
ESMA is also seeking input on potential changes such as:
- Modifying reporting channels.
- Introducing direct reporting to ESMA.
- Transferring to trading venues the obligation to report on-venue transactions.
- Assessing the cost implications for different market participants.
While the consultation remains open, the direction of travel ESMA is taking signals a potential game-changer intended at simplifying the EU’s regulatory framework.
Collaborating with customer focus
Our regulatory services team is currently analysing the call for evidence and working on a response. The goal: to contribute constructively to the regulatory debate and promote the integrity and competitiveness of the EU securities market.
In parallel, we continue to engage with supervisory authorities and clients to ensure timely implementation of changes to RTS 1 and RTS 2, which concern transparency for equity and non-equity instrument.
Our comprehensive reporting offering spans transaction reporting solutions (via ARM or ATR for MiFIR and Regis-TR’s Trade Repository offering for EU and UK EMIR), real-time publication of Systematic Internalisers’ firm quotes (pre-trade transparency), and post-trade publication of OTC trades through our Approved Publication Arrangement (APA) solution.
We stand ready to assist our clients throughout their MiFIR and EMIR compliance journey. At every step of the way, we support them in implementation of eventual changes, ensuring a smooth and successful transition.