ESMA’s New MiFIR Data Quality Framework
Key Takeaways
- ESMA’s DQEF signals a shift from basic transaction report submission towards ongoing data quality supervision.
- The framework does not add new reporting fields, but it raises expectations around the quality, accuracy and consistency of existing MiFIR Article 26 transaction reporting data.
- Regulators are increasingly using data analytics, exception monitoring and risk-based supervision to identify recurring reporting issues and poor data quality trends.
- Firms need stronger governance across the full reporting lifecycle, including reconciliation, exception management, remediation tracking and evidence of control effectiveness.
- Reporting tools must go beyond successful submission and support continuous visibility, operational resilience and data quality oversight.
In May 2026, ESMA published its MiFIR Article 26 Transaction Data Quality Engagement Framework (DQEF), signalling a further step towards more proactive and data driven supervision of transaction reporting across Europe.
While transaction reporting has long focused on submission completeness and timeliness, the DQEF places increasing emphasis on the ongoing quality, accuracy and consistency of reported data. For firms subject to MiFIR reporting obligations, this represents an important shift in supervisory expectations
What is the DQEF?
The Data Quality Engagement Framework, or DQEF, is ESMA’s new supervisory framework designed to strengthen how National Competent Authorities (NCAs) monitor and engage with firms on transaction reporting data quality issues under MiFIR Article 26.
The framework establishes a more structured and harmonised approach for identifying, escalating and remediating transaction reporting data quality concerns across the EU.
Importantly, the DQEF is not introducing new reporting fields or technical requirements. Instead, it focuses on how regulators assess the quality of the data firms are already submitting.
Under the framework, NCAs will increasingly rely on data analytics, exception monitoring and risk based supervision to identify firms exhibiting recurring reporting issues, anomalies or poor data quality trends.
The objective is clear. Regulators want reporting data that is not only submitted on time, but also accurate, consistent and genuinely usable for market oversight purposes.
Why the DQEF Matters
The publication of the DQEF reflects a broader regulatory trend that has become increasingly visible across MiFIR, EMIR and other reporting regimes.
Regulators are moving away from simply collecting large volumes of data and are instead focusing on the effectiveness and reliability of the information they receive.
For firms, this means transaction reporting can no longer be viewed as a static compliance exercise. Data quality controls, reconciliation processes and exception management are becoming increasingly important components of supervisory scrutiny.
The DQEF also reinforces a growing expectation that firms maintain robust governance around transaction reporting data throughout the reporting lifecycle.
This includes:
- identifying reporting anomalies quickly
- investigating recurring issues
- maintaining clear remediation processes
- evidencing ongoing oversight and control effectiveness
Firms operating fragmented reporting environments may find this particularly challenging, especially where reporting data passes through multiple systems, enrichment layers or regional workflows before submission.
The Operational Challenge
One of the key implications of the DQEF is that firms will need greater visibility into the quality of their reporting data on an ongoing basis.
Historically, many firms focused primarily on whether reports were successfully submitted. Under the DQEF, the focus increasingly shifts towards whether the underlying data itself is reliable and internally consistent.
This creates operational pressure in several areas:
- reconciliation and exception management
- control framework effectiveness
- data lineage and traceability
- root cause analysis
- cross jurisdiction consistency
As reporting obligations continue to expand across multiple jurisdictions, maintaining this level of oversight across different reporting regimes and time zones becomes significantly more complex.
Looking Ahead
The DQEF is another clear indication that transaction reporting supervision is changing.
The focus is shifting from volume towards quality. From submission towards oversight. And from isolated reporting obligations towards broader operational accountability.
For firms, the challenge is no longer simply whether reports are being submitted, but whether reporting frameworks are capable of delivering the level of consistency, transparency and control regulators increasingly expect.
For further reading, review the full ESMA MiFIR Article 26 Transaction Data Quality Engagement Framework (DQEF) .
How Qomply can help
At Qomply, we have seen growing industry focus on data quality, reconciliation and reporting oversight across reporting regimes including MiFIR, EMIR, SFTR, CFTC, MAS, ASIC and HKMA.
The DQEF reinforces the importance of having reporting tools capable of providing firms with greater visibility, control and operational resilience across the reporting lifecycle.
Qomply’s platform is designed to help firms monitor reporting quality more effectively through:
- real time exception monitoring
- reconciliation and control workflows
- data quality oversight
- issue investigation and remediation tracking
- follow the sun operational support
As regulators continue placing greater emphasis on reporting quality and supervisory usability, firms increasingly require reporting frameworks that go beyond submission alone and support ongoing operational governance.
Frequently asked questions
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ESMA’s MiFIR Article 26 Data Quality Engagement Framework, or DQEF, is a supervisory framework designed to help National Competent Authorities monitor and engage with firms on transaction reporting data quality issues. It focuses on the quality, accuracy and consistency of data already submitted under MiFIR Article 26.
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No. The DQEF does not introduce new reporting fields or technical requirements. Instead, it changes how regulators assess the quality of existing transaction reporting data submitted by firms.
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The DQEF matters because regulators are moving beyond submission completeness and timeliness. Firms are increasingly expected to demonstrate that their transaction reporting data is accurate, consistent, reliable and usable for market oversight.
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The DQEF increases pressure on firms to improve reconciliation, exception management, data lineage, root cause analysis and cross-jurisdiction consistency. Firms with fragmented systems, multiple enrichment layers or regional workflows may face greater complexity.
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Firms can prepare by strengthening data quality controls, improving exception monitoring, maintaining clear remediation processes, evidencing oversight, and ensuring reporting data remains reliable throughout the reporting lifecycle.
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