When ESMA convened its first ‘Data Day’ on 2 December 2025, the agenda title – “Burden reduction in the digitalisation era” – captured a shift that has been building across Europe’s regulatory landscape for several years. While markets been advancing shared data models and machine-executable reporting logic through initiatives such as the Common Domain Model (CDM) and Digital Regulatory Reporting (DRR), supervisors are now publicly moving in the same direction – see Redefining Digital Regulatory Reporting with CDM & DRR. Data Day didn’t introduce new technical requirements, but it created something the market has been waiting for: a formal, recurring supervisory forum for alignment within ESMA’s simplification framework, backed by near-term milestones and an expectation of visible progress before the next annual event.
ESMA’s own framing of Data Day is unambiguous. The authority states that the event examines “how smarter data use and digitalisation can simplify the regulatory framework and reduce reporting burdens while steering clear of deregulation.” The programme anchors Data Day within ESMA’s broader Simplification and Burden Reduction (SBR) work, which identifies duplication across reporting regimes and seeks to streamline obligations without compromising supervisory coverage.A central feature of the SBR agenda is ESMA’s acknowledgment that current reporting requirements across MiFIR, EMIR and SFTR often involve overlapping data elements captured through parallel processes. ESMA’s published materials describe the need to avoid duplications and streamline reporting, and the Data Day sessions were organised explicitly around this theme. Importantly, ESMA identifies concrete examples where reporting duplication can be eliminated through better use of existing datasets.
One of the most notable commitments already embedded in ESMA’s supervisory process is the decision to use MiFIR Article 26 transaction data to conduct transparency and volume-cap calculations. ESMA notes that once the revised equity transparency RTS apply and ESMA switches transparency calculations to MiFIR transaction data (planned around the turn of 2025/2026), those metrics will be derived directly from transaction reports, allowing the dedicated FITRS/DVC venue-submitted data flows to be decommissioned. This approach mirrors the market’s long-standing argument for reusing authoritative transaction datasets rather than requiring bespoke reporting templates.Crucially, Data Day introduces a formal annual checkpoint. The event’s closing session is dedicated to “strategic priorities for the coming years”, with emphasis on the outcomes expected by the next Data Day in 2026.
ESMA’s Call for Evidence on a Comprehensive Approach to Reporting supplies the policy framework beneath this discussion. Published earlier in 2025, the document outlines two structural options:
- Option 1, aimed at eliminating duplicate reporting obligations, is projected to be achievable within roughly five years.
- Option 2, a more ambitious “report once” template, is expected to require five to seven years.
Data Day gives these options a live forum for debate, enabling industry participants to articulate practical requirements and constraints. That consultative structure helps turn simplification from a conceptual objective into a phased policy roadmap.
2026 Expectations
Although Data Day itself does not create new rules, regulators already have several time-bound commitments that will deliver visible changes over the next 12 months.
The most immediate is ESMA’s confirmed plan to switch transparency and volume-cap calculations over to MiFIR transaction data. ESMA states that the transparency calculations will be published once revised Regulatory technical Standards (RTS) enter into force, expected by the end of 2025. This shift marks a significant change in how supervisory analytics are powered, and reinforces ESMA’s direction of travel toward consolidated, high-quality data rather than multiple reporting channels.
In parallel, ESMA’s simplification roadmap establishes a clear policy milestone: a Final Report on financial-transaction reporting simplification will be published in the first half of 2026. The report will consolidate feedback from the Call for Evidence, determine which of the simplification options will proceed, and outline follow-up work.
A series of incremental but meaningful changes are also underway through the MiFIR Review. ESMA has signalled work on aligning specific transaction-data fields with EMIR and consolidating reference-data requirements. These adjustments, while technical, contribute to the broader objective of improving data consistency across regulatory regimes.
Meanwhile, the UK supervisory authorities are progressing their own digitalisation agenda. The FCA and Bank of England’s Transforming Data Collection (TDC) programme continues to focus on standardised data collections, improved reporting instructions, and better definitions of regulatory data. These published commitments reflect a similar philosophy to ESMA’s: build consistent data collections that reduce cost and improve usability for supervisors.
CDM/DRR Alignment
While regulators refine policy and supervisory expectations, the market has already built a technical foundation compatible with ESMA’s objectives.
The Common Domain Model (CDM), under FINOS governance provides an open, cross-industry standard for lifecycle events, state transitions, and the semantic definitions that underpin post-trade and reporting processes. Originally developed by ISDA for OTC derivatives, the CDM has already been extended by the International Capital Markets Association (ICMA) for repos and bonds and is currently being extended by the International Securities Lending Association (ISLA) for securities lending.
In parallel, ISDA Digital Regulatory Reporting (DRR) is already in live use. DRR has been implemented for the CFTC rewrite and EMIR Refit, with publicly stated plans to cover a total of 12 supported regimes across 9 jurisdictions globally. DRR provides machine-executable logic for regulatory rules, enabling firms and infrastructures to automate reporting derivation directly from structured lifecycle data.
Although ESMA does not reference CDM or DRR in Data Day materials, its simplification objectives are directly aligned with the capabilities these frameworks already deliver. CDM offers the lifecycle-based, harmonised data foundation that ESMA wants to see across MiFIR, EMIR and SFTR. DRR provides the machine-readable rule logic that ESMA’s digitalisation goals anticipate.
Subscribe to our newsletter
