The European Securities and Markets Authority has told Brussels that merging three overlapping transaction reporting regimes into a single “report once” framework could save financial firms up to €1 billion a year.
ESMA published the final report on 2 July, closing a call for evidence into reporting costs under MiFIR, EMIR and SFTR (ESMA). The plan rests on one idea: file trade data once and let supervisors reuse it across all three regimes.
“Transaction reporting is central to market transparency, risk monitoring and detecting market abuse,” said Verena Ross, ESMA’s chair. “Over time, fragmentation has led to duplication, inconsistent requirements and increased costs for market participants and authorities. Our analysis shows that a ‘report once’ approach can significantly reduce costs while improving the quality and usability of data for supervisors.”
Three regimes, one trade, one range
EMIR covers derivatives, MiFIR covers trading in financial instruments generally, and SFTR covers securities lending and repo. ESMA puts current annual operating costs for the three regimes combined at €1.0 billion to €4.2 billion across the market, so a €1bn saving is measured against a baseline up to four times that size.
ESMA’s cost-benefit analysis puts annual net savings at €250 million to €1.0 billion, a 22% to 24% cut in recurring costs, close to the European Commission’s target of cutting administrative burden on business by at least 25% over its 2024-2029 mandate (European Commission).
Where a firm lands on that range depends on a choice ESMA has flagged rather than settled: how much dual-sided reporting under EMIR and SFTR, where both counterparties report the same trade separately, gets removed. ESMA names the resulting reconciliation as a top cost driver.
Michele Hillery, head of repository and derivatives services at trade repository operator DTCC, welcomed the direction without treating the number as settled, calling it “an opportunity to build a streamlined reporting framework that reduces complexity while improving the quality and consistency of reported transaction data” (A-Team Insight).
A tight timeline to 2031
Nothing about the €1bn arrives soon. ESMA’s recommendations still need “targeted legislative changes, a phased implementation and an inclusive dialogue with industry technical experts” before taking effect, the authority said. A legal update from Linklaters sets out the path: Level 1 changes targeted for mid-2028, Level 2 templates by mid-2029, IT build and deployment by mid-2030 (Linklaters), then a 12 to 18 month firm testing window before going live from late 2031 at the earliest.
It is one half of ESMA’s wider regulatory reporting simplification push, alongside parallel work on fund reporting launched in 2025.
Kaizen’s warning: less duplication, more scrutiny
Not every reaction has focused on the money. Tim Hartley, EMIR reporting director at compliance firm Kaizen, told The Trade News the reform raises the bar on accuracy even as it cuts workload: “‘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 Trade News).
Three separate filings today give supervisors a rough cross-check on each other; get one wrong and the other two can still flag it. Collapse that into one record and there is no second filing left to catch an error. Most exposed are firms filing under more than one regime already: banks reporting derivatives under EMIR while also meeting MiFIR obligations.
Regtech’s fix: reuse the plumbing that already exists
The technical question ESMA has not answered is how a single format gets built and kept consistent across firms with different systems. Leo Labeis, chief executive of REGnosys, which has maintained the Common Domain Model for trade associations ISDA, ICMA and ISLA since 2018, argued the answer already exists.
“Fragmentation across MiFIR, EMIR and SFTR creates unnecessary cost and complexity, even as the potential savings from simplification are significant,” Labeis said. “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 and shared standards such as the Common Domain Model can make a real difference.”
ESMA itself has not named the Common Domain Model; its language stops at a “single, modular set of reporting templates.” The case for the CDM is REGnosys’s argument for how ESMA’s ambition gets built, not a design ESMA has confirmed, part of a broader pattern of compliance infrastructure being rebuilt around machine-readable rules.
MiFIR, EMIR and SFTR are EU regulations, so amending them runs through the European Parliament and the Council, not ESMA alone, which is why Level 1 change is not due until 2028. Until then, firms hold three separate reporting obligations for the trades they do today.
