ESMA has turned the long-running industry case for “report once” transaction reporting into a staged policy programme for rebuilding EU reporting around reusable, controlled transaction data. Its Final Report On the Call for Evidence recommends a single integrated framework across the Markets in Financial Instruments Regulation (MiFIR), European Market Infrastructure Regulation (EMIR) and Securities Financing Transactions Regulation (SFTR), supported by near-term relief on delegated reporting, intragroup exemptions, back-reporting, reconciliation and selected low-value fields. The cost case is significant, with ESMA estimating €250 million to €1.0 billion in annual net savings and a 22% to 24% reduction in recurring operating costs. The implementation issue for firms is sharper: reducing duplicate submissions will place greater weight on the quality, lineage and governance of the data that remains.
The current landscape has become costly because obligations have grown through parallel frameworks. Each regime has its own channels, templates, validation rules and controls. ESMA identifies the main burden drivers as unsynchronised regulatory change, duplication across frameworks and channels, and dual-sided reporting with reconciliation. Current annual operating costs are estimated at €1.0 billion to €4.2 billion.ESMA Chair Verena Ross framed the objective as a balance between efficiency and supervisory value. A “‘report once’ approach can significantly reduce costs while improving the quality and usability of data for supervisors,” she said. ESMA’s target model is a single integrated framework, with transaction data reported once through a common modular structure and reused across authorities and supervisory mandates.
ESMA says “report once” cannot be achieved by merging legal obligations while keeping existing reporting chains intact. The future framework must redesign how data is collected, processed, validated and transmitted, with fewer submission points, consistent formats and stronger controls across the reporting chain.
Michele Hillery, Managing Director, Head of Repository & Derivatives Services at DTCC, described the Final Report as an important step towards harmonisation. “ESMA’s decision to advance a “report once” framework in the longer-term marks an important step toward a more standardized, efficient, and aligned reporting framework,” she said. She added that implementation creates “an opportunity to build a streamlined reporting framework that reduces complexity while improving the quality and consistency of reported transaction data.”
Tim Hartley, EMIR Reporting Director at Kaizen, framed the same issue from a reporting controls perspective. He described the Final Report as “an important marker”, adding: “‘Report once’ could reduce duplication and operational burden over time, but it will also place even greater emphasis on data quality and controls across regimes.”The implementation challenge sits in the relationship between lower duplication and higher reliance on shared data. Under today’s model, dual reporting and trade repository reconciliation create operational cost, but they also serve a key control function by exposing breaks and inconsistencies. ESMA’s model reduces those frictions and moves control closer to source systems, delegated reporting arrangements and firms’ internal evidence of completeness, accuracy and timeliness.
The compromise is visible in ESMA’s treatment of single-sided reporting. Industry has argued that dual-sided reporting under EMIR and SFTR creates disproportionate pairing, matching and correction work. ESMA agrees that reconciliation is a major cost driver but does not recommend a full transition to single-sided reporting noting that it would remove independent data points used to assess consistency and completeness, reducing information quality for authorities.
Instead, ESMA recommends expanding delegated reporting, especially for trades between financial counterparties and non-financial counterparties. The obligation would sit with the counterparty best placed to fulfil it. For other counterparty combinations, ESMA wants flexibility at Level 2 and Level 3. The important point for firms is that delegated reporting still requires data-quality safeguards, information exchange and internal controls by both reporting and non-reporting entities.
The short- and medium-term measures reinforce that practical direction. ESMA proposes expanded delegated reporting, streamlined EMIR intragroup exemption procedures, reduced back-reporting, targeted MiFIR exemptions, selected MiFIR field deprioritisation, EMIR reconciliation adjustments, errors-and-omissions simplification and narrower SFTR reporting where settlement fails before the reporting deadline. These measures provide relief while avoiding sunk costs before the long-term framework.
For firms, the immediate task is to prepare before final templates harden. That means reviewing cross-regime data models, ownership, lineage, delegated-reporting oversight, pre-submission validation, exception workflows and audit evidence. ESMA’s implementation path depends on Level 1 legislative change, Level 2 templates, IT development and a 12- to 18-month market implementation period, with a fully integrated solution possible towards the second half of 2031.
Leo Labeis, CEO and Founder of REGnosys, links the policy goal to a standards-based implementation path. “The challenge now is to make ‘report once’ work in practice without losing the detail supervisors need, and that is where common data models, digital regulatory reporting (DRR) and shared standards such as the Common Domain Model (CDM) can make a real difference.” He adds: “The foundations already exist to make reporting more standardised, reusable and consistent across regimes, and the opportunity now is to turn the ‘report once’ ambition into a practical framework that improves data quality while reducing burden.”
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