As Europe accelerates its shift toward data-driven supervision, the conversation has moved far beyond compliance. Today, the focus is on quality, efficiency, interoperability, and sustainability of the reporting ecosystem, core themes that underpin ESMA’s Data Day: Burden Reduction in the Digitalisation Era.
Trade and transaction reporting sits at the heart of this agenda, and the simplification proposals presented, both short-term “quick wins” and longer-term system reform, mark a meaningful step towards a more harmonised and less burdensome regulatory environment.
Short-Term Simplification: Quick Wins with High Impact
ESMA’s short-term recommendations target areas where complexity and reporting frictions provide little supervisory value. These are pragmatic changes that can deliver immediate relief for firms without compromising data quality.
| Details | How Point Nine (P9) can help | |
| Remove ETDs from EMIR Reporting | ETDs are already captured under MiFIR, and duplication between regimes creates unnecessary reconciliation work without enhancing oversight. Eliminating ETDs from EMIR would align the EU with other global regulators, such as the CFTC and the HKMA. | P9 already classifies instrument eligibility across EMIR and MiFIR using automated checks against FIRDS, FIRDS-GB and internal logic. Removing ETDs can be seamlessly managed by adjusting eligibility logic; no client-side development is required. |
| Exclude SFTs with Central Banks from MiFIR | These transactions are sufficiently covered under MMSR. Their relevance for market abuse monitoring is limited, yet they generate non-trivial reporting volumes. | P9’s data ingestion rules can flag and remove SFTs involving central banks at source, ensuring clean, compliant submissions without operational overhead for clients. |
| Reduce EMIR/SFTR Reconciliation Fields to Essential Ones Only | Current reconciliation includes fields that often rely on internal valuation models, floating-rate conventions, or broker-specific methodologies, leading to systematic mismatches.
Reducing the scope to essential, verifiable fields and applying reasonable tolerances would materially lower false breaks and focus supervisory attention where it matters. |
P9’s reconciliation dashboards already differentiate between “material” and “noise” mismatches. With fewer mandatory reconciliation fields, P9 clients would see:
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| Remove Dual-Sided Reporting Where It Adds No Value | For NFC- or agent-lending scenarios, the second report often provides little incremental insight and is typically auto-generated. | P9 already supports delegated reporting and controlled auto-generation. A shift to single-sided reporting would reduce client costs significantly and remove a major source of pairing issues. |
| Promote Global Identifiers and Avoid EU-Specific Codes | Consistent use of LEI, UPI, CFI, UTI and avoiding region-specific taxonomies strengthens interoperability and reduces mapping errors. | P9’s platform is identifier-driven: |
| Limit Static and Reference Data Re-Reporting | Large parts of transaction reports are static and already available in central reference databases. Re-reported data creates unnecessary noise and bandwidth consumption. | P9 is already optimised to avoid re-submitting static instrument details unnecessarily. Delegating this to ESMA’s Data Hub (via UPI or FIRDS) could cut up to 20–30% of daily outbound volume for some clients. |
| Remove Low-Value FIRDS Obligations for SIs/DPEs | FIRDS obligations for SIs/DPEs often yield limited supervisory benefits while generating substantial technical load. | As a provider that processes FIRDS updates daily, P9 supports any move that rationalises reference data workload and reduces duplication. |
| Harmonise ESMA/NCA Validation and Feedback Rules | Diverging NCA practices are one of the biggest burdens on firms. A single validation and feedback framework would reduce resubmissions and provide equal treatment across the EU. | P9 already normalises and interprets feedback across NCAs, but harmonisation would streamline operations even further. Clients benefit immediately from consistent error classification and remediation logic. |
| Establish a Cross-Regime Data Dictionary | Currently, EMIR, MiFIR and SFTR definitions diverge on key terms (valuation, collateral, notional logic, lifecycle concepts). A unified dictionary would dramatically reduce interpretative gaps. | As a multi-regime reporting provider, P9 is already positioned to map equivalent fields across frameworks. A formal cross-regime dictionary would allow us to simplify ingestion templates and reduce client onboarding timelines by up to 40%. |
Long-Term Vision: Single Reporting Through ESMA’s Data Hub
The long-term proposal centralising reporting via ESMA’s Data Hub represents a transformational step. One format, one channel, one central validation engine.
Core Principles:
- A unified submission format
- ESMA-managed validation with NCA supervisory overlay
- Optional use of intermediaries (TRs, ARMs, service providers)
Key Limitations
- Diverging political views and capacity concerns
- High technical complexity
- Need for an EU-level steering task force
- Long implementation horizon (this is not a 2026–2027 project)
How Point Nine (P9) can help
As a service provider already handling multi-regime, multi-jurisdiction routing, P9 is well-placed to become a connectivity layer to the future Data Hub.
We can support:
- format transformation
- validation pre-checks
- enrichment through UPIs and reference data
- lifecycle tracking
- reconciliation and exception management
- long-term migration planning
What This Means for the Industry
The direction is clear: less reporting volume, fewer duplications, better data quality, and a more efficient EU reporting ecosystem.
These proposals also align with global convergence trends CFTC rewrite, ASIC rewrite, HKMA OTC reporting, MAS 2.0 all moving toward:
- global identifier
- machine-readable rulebooks
- simplified validations
- reduced duplication
ESMA’s approach positions Europe as a thought leader in supervisory technology.
How P9 Can Support Firms Through These Changes
Point Nine has been operating in the post-trade regulatory space since 2014, delivering a fully managed reporting service across EMIR, MiFIR, SFTR, ASIC, MAS and more.
We are uniquely positioned to support the burden-reduction agenda:
- Instant Adaptability: Our rules engine allows changes such as removing ETDs or adjusting SFT eligibility to be deployed centrally with no client-side coding.
- Strong Data Quality Framework: We already mirror ESMA’s validation logic and integrate daily FIRDS, FIRDS-GB, and ANNA-DSB data.
- Reconciliation Optimisation: Our dashboards highlight material mismatches, which fit naturally with proposals to reduce reconciliation scope.
- A Single Reporting Gateway: Whatever the final architecture, TRs, NCAs, ARMs, or ESMA Data Hub. P9 acts as a unified entry point, reducing complexity for clients.
- Advisory and Migration Support: We regularly guide clients through new regulatory implementations (EMIR Refit, MiFIR changes, ASIC rewrite). The same expertise applies to the simplification agenda.
Conclusion
ESMA’s simplification proposals are not only timely, but they’re also necessary. As financial markets scale, the cost of reporting cannot grow linearly with it. Smarter, technology-enabled, identifier-driven reporting is the future.
The combination of burden reduction + digitalisation + supervisory convergence will reshape how Europe collects and uses financial data in the next decade.
Firms will benefit. Supervisors will benefit. And the entire reporting chain service providers like P9, included will play a central role in making this transformation a reality.
