The European Securities and Markets Authority has proposed a major redesign of EU transaction reporting, saying a new “Report Once” framework could save market participants between €250 million and €1 billion a year while reducing recurring reporting costs by 22% to 24%.
In its final report, ESMA said transaction reporting under MiFIR, EMIR and SFTR has become fragmented, duplicative and expensive because requirements have expanded through separate regulatory regimes. The regulator now wants a single modular framework that allows firms to report transaction data once and make that information reusable across multiple supervisory mandates.
The reform is more than a technical reporting cleanup. If implemented, it would change one of the most expensive operational layers in European financial markets, affecting banks, brokers, buy-side firms, CCPs, trade repositories, non-financial corporates and RegTech providers.
The Numbers Behind ESMA’s Proposal
| Metric | ESMA Estimate |
|---|---|
| Current annual operating costs | €1.0 billion to €4.2 billion |
| Annual net savings | €250 million to €1.0 billion |
| Recurring cost reduction | 22% to 24% |
| 10-year discounted net benefits | €1.2 billion to €4.9 billion |
| Implementation cost recovery | Year 3 or 4 |
| Supervisory cost reduction | 9% to 11% |
The figures come from ESMA’s cost-benefit analysis and supporting factsheet. The regulator estimates current annual operating costs for transaction reporting at between €1.0 billion and €4.2 billion. Under the preferred long-term structure, the industry could recover implementation costs within three to four years and then benefit from sustained annual savings.
Why Reporting Became So Expensive
Transaction reporting is meant to help regulators monitor markets, detect abuse, assess systemic risk and protect investors. Over time, however, Europe’s reporting framework has expanded across multiple regimes, particularly MiFIR for financial instruments, EMIR for derivatives and SFTR for securities financing transactions.
Each framework was built for legitimate supervisory reasons. The problem is that they developed separately.
ESMA said the main cost drivers are frequent and unsynchronised regulatory changes, duplicative reporting across different frameworks and channels, and dual-sided reporting with associated reconciliation processes.
In practice, firms often report economically similar transactions several times through different routes, using different definitions, schemas, controls and reporting infrastructures. That creates duplicated technology, duplicated operations and duplicated error management.
Education: What MiFIR, EMIR And SFTR Cover
| Regime | Main Focus | Why It Matters |
|---|---|---|
| MiFIR | Transaction reporting for financial instruments | Supports market abuse detection and market transparency |
| EMIR | Derivatives reporting, clearing and risk controls | Helps regulators monitor OTC derivatives and systemic risk |
| SFTR | Securities financing transactions | Improves transparency around repo, securities lending and reuse |
The issue is not that these regimes are unnecessary. ESMA explicitly says transaction reporting remains central to market transparency, risk monitoring and detecting market abuse. The reform aims to preserve supervisory value while removing duplication and unnecessary cost.
What “Report Once” Means
The Report Once model would create a single integrated transaction reporting framework across MiFIR, EMIR and SFTR. Instead of firms submitting overlapping reports into separate regulatory silos, transaction data would be reported once through a common modular structure.
That data could then be reused by different authorities for different supervisory purposes.
ESMA says the model would use one type of reporting infrastructure, structural simplification and a design that addresses the root causes of current cost drivers. The framework would still account for product-specific reporting needs, but within one integrated architecture.
| Current Model | Report Once Model |
|---|---|
| Separate reporting regimes | Single integrated framework |
| Multiple reporting channels | Single type of infrastructure |
| Duplicative submissions | Reusable transaction data |
| Unsynchronised rule changes | More coordinated change management |
| Dual-sided reconciliation burden | Simplified delegation and reconciliation structure |
The Three Biggest Cost Drivers
ESMA’s final report identifies three structural sources of cost.
The first is regulatory complexity created by frequent and unsynchronised changes. Firms have to update reporting systems repeatedly as MiFIR, EMIR and SFTR evolve on different timelines. ESMA says change-management costs can be of a similar order of magnitude to recurring run costs for major reporting entities.
The second is duplicative reporting and fragmented channels. Derivatives and other transactions can be reported multiple times under different regimes, requiring parallel pipelines, controls and connectivity.
The third is dual-sided reporting under EMIR and SFTR, where both counterparties report the same transaction, creating pairing, matching, exception management and correction processes. ESMA says reconciliation activities absorb a substantial share of ongoing reporting effort without always delivering equivalent supervisory value.
Short-Term Relief Before The Full Overhaul
ESMA does not expect the Report Once framework to arrive immediately. The final report recommends a staged approach, combining long-term structural reform with short and medium-term relief measures.
The short-term measures include reducing back-reporting, targeted exemptions from MiFIR RTS 22 requirements, deprioritising selected MiFIR fields, adjusting EMIR reconciliation, simplifying SFTR reporting of settlement fails and simplifying errors and omissions notifications.
| Timing | Measure |
|---|---|
| Medium-term | Revision of dual-sided reporting |
| Medium-term | Streamlining intragroup reporting exemption procedures |
| Short-term | Reduction of back-reporting |
| Short-term | Targeted exemptions from MiFIR RTS 22 |
| Short-term | Deprioritising targeted MiFIR fields |
| Short-term | Adjustment of EMIR reconciliation |
| Short-term | Simplification of SFTR reporting settlement fails |
| Short-term | Simplification of errors and omissions notifications |
Who Benefits Most?
The biggest beneficiaries are likely to be large banks, brokers and investment firms that maintain multiple reporting pipelines across MiFIR, EMIR and SFTR. Buy-side firms and non-financial corporates could also benefit from reduced operational burden, especially where delegated reporting becomes easier.
Deloitte’s cost-benefit analysis, prepared for ESMA, found that non-financial corporates, sell-side firms and buy-side firms should realise cost reductions from a move to the Report Once model. Market infrastructure firms have a more mixed outlook, with some facing higher costs or revenue pressure if reportable volumes decline.
That makes the reform both a cost-saving opportunity and a competitive threat. Reporting vendors, trade repositories and technology providers that currently benefit from fragmented reporting workflows may see demand shift toward integrated, modular reporting infrastructure.
Why RegTech Providers Should Pay Attention
The Report Once model could reshape the RegTech market.
Today, many firms use separate systems, service providers and control frameworks to comply with MiFIR, EMIR and SFTR. If ESMA’s model is implemented, demand may move away from siloed reporting tools and toward platforms capable of handling cross-regime data models, common identifiers, validation, data lineage, exception management and supervisory reuse.
That is likely to favour vendors with strong data architecture, modular workflows and the ability to adapt to future reporting standards.
Implementation Timeline
ESMA’s factsheet sets out a long implementation path. The call for evidence was launched in June 2025, feedback closed in September 2025, the interim report was published in May 2026, and the final report was published on July 2, 2026. The long-term Report Once framework depends on completion of the relevant legislative cycle, followed by full integrated framework development and a go-live after a post-implementation lead time.
| Date / Stage | Milestone |
|---|---|
| June 2025 | Call for evidence launched |
| September 2025 | Feedback deadline |
| May 2026 | Interim report, CBA workshops and public hearing |
| July 2026 | Final report published |
| Next stage | EU institutional discussions and legislative work |
| Long-term | Integrated Report Once framework and go-live |
The Risk: Simplification Cannot Weaken Supervision
The main challenge is preserving data quality.
Supervisors rely on transaction reporting for market abuse surveillance, systemic risk monitoring, financial stability analysis and policy decisions. ESMA’s simplification principles therefore stress that reform must preserve information value, reduce overlaps, pursue global alignment and balance costs against benefits.
That makes implementation difficult. Removing duplication is attractive, but regulators cannot afford to lose critical data. The final framework will need to decide which fields are genuinely useful, which can be removed and how data can be reused without creating gaps.
Outlook
ESMA’s Report Once proposal is one of the clearest examples of Europe trying to reduce regulatory burden without abandoning post-crisis transparency standards.
The political appeal is obvious. A system that costs up to €4.2 billion a year to operate, while forcing firms to report overlapping information through fragmented channels, is an obvious candidate for reform. The potential annual savings of up to €1 billion give policymakers a concrete reason to act.
But the operational challenge is equally clear. Transaction reporting is embedded deeply inside bank systems, broker workflows, CCP infrastructure, trade repositories and supervisory data platforms. Rebuilding that architecture will take legislation, technical standards, industry coordination and years of implementation.
If successful, however, Report Once could become a template for future EU regulatory simplification: fewer duplicate reports, better data quality, lower costs and a reporting system built around reuse rather than repetition.