Beyond ESMA: (Part 2) What the Interim Report Means for Global Reporting

Although European Securities and Markets Authority (ESMA)'s Interim Report focuses on European reporting frameworks, its implications reach far beyond Europe. Together with the FCA's recent consultation, it signals a broader shift in regulatory thinking that global firms should not ignore.

For years, transaction reporting programmes have been designed around individual regulations. Firms built separate solutions for MiFIR, EMIR, SFTR, CFTC, MAS, ASIC, HKMA and other regimes as they were introduced. While each programme addressed its immediate regulatory objective, the cumulative result has been duplicated processes, inconsistent governance and increasingly complex reporting architectures.

The conversation is now changing. Regulators are focusing less on the volume of data submitted and more on the quality, consistency and interoperability of that data. Harmonisation is no longer simply about reducing operational burden; it is about enabling more effective market supervision.

This creates several strategic priorities for firms.

First, reporting architectures need to become more adaptable. Systems designed around isolated regulations are unlikely to support future harmonisation efficiently.

Second, data governance becomes increasingly important. Consistent data lineage, enrichment rules and reconciliation processes will be critical as regulators seek greater alignment across reporting frameworks.

Finally, operational resilience should be viewed as part of the reporting strategy. Global reporting obligations operate continuously across jurisdictions and time zones, requiring firms to manage exceptions and maintain oversight around the clock.

The message emerging from ESMA and the FCA is not that reporting obligations are disappearing. Rather, expectations are evolving. Regulators increasingly expect firms to deliver high-quality, consistent and interoperable reporting data through resilient operating models.

For firms, the opportunity is clear. Those that invest now in integrated reporting capabilities will be better positioned to respond to future regulatory change, reduce operational complexity and improve data quality. In an environment where harmonisation is gathering momentum, transaction reporting should be viewed not as a series of individual compliance exercises, but as a strategic global capability.