As regulators look to simplify transaction reporting and reduce duplication across regimes, Leo Labeis, CEO of REGnosys, explores how “report once”, common data standards and digital regulatory rules could lay the foundations for a longer-term shift from push to pull-based reporting.
For years, regulatory reporting has asked firms to solve essentially the same problem repeatedly. Firms take transaction data, interpret a set of rules and turn it into the report required by a particular regime, then repeat the process for the next obligation or jurisdiction.
Interpretation is not always straightforward. Reporting rules do not necessarily map neatly to particular products or transactions, leaving firms to fill in the gaps and work through ambiguities in industry forums, guidance and Q&As. That adds cost, delays implementation and can create compliance risk when firms are forced to interpret for themselves what a rule requires.Changing those rules can also be a lengthy process. Reporting reforms can take years to move from consultation through technical specifications and implementation, while different regimes evolve on different timelines. For firms subject to several regimes, the result can feel like continuous change, with one reporting update implemented while another is already on the horizon, leaving little room to address the underlying architecture.
Regulators are increasingly looking to change that. In the EU, ESMA is considering a “report once” approach across MiFIR, EMIR and SFTR, while in the UK, the FCA and Bank of England have set up a task-force to examine the long-term harmonisation of reporting across the same three regimes. ESMA estimates that simplification could deliver up to €1 billion in annual savings, while the FCA puts the savings from its latest reforms at £108 million a year.
De-duplication is an obvious response, but if regulators want firms to stop reporting the same facts repeatedly, the industry first has to agree on what those facts are. That means looking beyond individual reporting templates to the transaction data beneath them.
Report once changes the starting point
The traditional “push” model starts with a regulatory obligation. The regulator defines what it needs, and firms interpret the requirement and build the processes to extract, transform and submit the data. As EMIR, MiFIR and SFTR have developed with their own specifications and timelines, firms have often built reporting processes around each regime separately, sometimes using different systems and providers. That fragmentation adds cost, with firms maintaining multiple reporting processes and connectivity points while transforming and submitting the same underlying transaction data in different ways for different regulatory purposes.
“Report once” creates an opportunity to tackle that duplication at source. A trade has the same economic characteristics regardless of whether it is being viewed through EMIR, MiFIR or another reporting regime. What changes is the regulatory interpretation of those facts and the information a particular authority requires. Separating the two means firms can start from a consistent representation of the transaction and derive the appropriate regulatory output from it.
The UK, EU and other markets will continue to set their own requirements, but the transaction data on which those requirements operate can be represented more consistently. A common representation of the economic event, combined with regulatory rules that can be applied for each jurisdiction, makes reuse possible even where the reporting obligations themselves differ.
Making regulatory data reusable
The Common Domain Model (CDM) provides a standardised representation of financial transactions and their lifecycle events, independent of any single reporting regime. ISDA’s Digital Regulatory Reporting (DRR) adds a separate layer in which reporting requirements can be expressed as machine-executable rules and applied to that data. The economic event can therefore be represented once, while different regulatory interpretations are applied to it.
This does not require firms to rip out the reporting infrastructure they already have. CDM and DRR have expanded across jurisdictions and asset classes, and firms can introduce the model and digital rules incrementally alongside their own proprietary models and existing workflows.
Interoperability is important for the same reason. Work translating existing formats into CDM has shown how established standards like FpML can map to a common representation, while interoperability with protocols such as FIX can extend the same principle across other market workflows. The objective is not to put every institution on the same technology stack, but to make sure their infrastructure can express the same economic facts consistently.
That also changes how regulatory updates can be handled. Today, a new requirement can trigger changes to mappings, transformations, validations and reporting pipelines. If the transaction is already represented consistently and the regulatory interpretation sits in a digital rules layer, more of the change can happen in those rules rather than requiring another round of changes to the underlying data architecture.
From reusable data towards pull
Rather than firms producing and pushing separate reports for each regime, an authoritative data layer could make normalised transaction data available, from which regulators derive the views they need. The starting point would be a granular representation of the trade, with regulatory rules determining the information required for different supervisory purposes. Regulators could then change the questions they ask without requiring firms to reconstruct the underlying transaction each time.
That would require regulators and industry to agree on the normalised representation of the transaction, starting from the supervisory outcomes the data needs to support, alongside clear arrangements for permissions, data lineage, security, versioning and responsibility for errors. A publicly available model and transparent regulatory rules could also give both sides a more active role in how that representation evolves, rather than firms receiving a technical specification and each having to interpret it independently.
Practical questions remain around connectivity, mapping and responsibility for data quality. A future state of this kind would represent a substantial departure from reporting today and is better thought of as a target state that could be approached incrementally rather than something the industry moves to in one step.
“Report once” does not mean the industry is moving immediately to pull-based reporting. But in a future-state architecture, the two can work together. Firms would provide a consistent, granular representation of the underlying transaction, rather than producing separate reports for each regime, while regulators derive the views they need from that data. As the data becomes more consistent and the rules applied to it more digital, the question can gradually move from which report a firm needs to produce to which regulatory view needs to be derived from the data.
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