Transaction reporting
Staying ahead of regulatory reporting updates
Mike Channing
•
Head of Sales, UK and EMEA
April 2, 2025
In financial regulation, 2025 is a big year for reporting. From the EU’s revamped MiFIR framework to the SEC’s consolidated audit trail developments, the global reporting landscape is shifting in ways that will demand material investment and attention from compliance teams.
Increasingly, regulators are not only expanding the scope of data they require – they’re also raising their expectations around accuracy, timeliness, and consistency. For firms with cross-border operations, the challenge is compounded by the need to comply with multiple, often overlapping regimes.
In this article, we explore the most significant upcoming changes to regulatory reporting and what they mean for the financial industry.
One of the most sweeping changes to European transaction reporting is the MiFIR Refit, which officially applies from 28 February 2026. It represents the most substantial revision to the MiFIR reporting framework since its introduction in 2018, with more than 140 data fields affected.
The scope of these changes is broad. Among the most notable are:
• Revised data fields and validation rules: ESMA has introduced new fields, redefined existing ones, and updated validation logic. These changes are designed to improve the quality and usability of data received by regulators, but they also place a significant burden on firms to update schemas, re-map data, and test extensively.
• New instrument reference data requirements: The Refit brings in revised FIRDS (Financial Instruments Reference Data System) data standards, including changes to ISIN reporting and classification.
• Elimination of some reporting obligations: In a rare concession, certain redundancies have been removed. For example, firms will no longer need to report some ancillary data that was previously duplicated across different filings.
• LEI and counterparty data updates: More granular identification of counterparties, including natural persons, will be required – demanding careful handling of personal data alongside trade data.
For firms, the complexity of these changes should not be underestimated. Many legacy reporting systems were built to accommodate the original MiFIR schema and may require significant re-engineering. Migration planning, regression testing, and parallel running are critical steps to ensure continuity and compliance.
While EMIR Refit technically went live in April 2024, many firms are still working through the operational implications. The regime overhaul significantly expanded the number of reportable fields and aligned EU derivatives reporting more closely with global standards (specifically ISO 20022 and the CPMI-IOSCO Critical Data Elements).
Key ongoing challenges include:
• Data quality remediation: ESMA and national regulators have been conducting data quality reviews and issuing feedback. Firms that struggled with the initial transition are now facing pressure to remediate outstanding issues.
• Reconciliation requirements: Enhanced reconciliation expectations between counterparties mean firms need robust matching processes and clear escalation procedures for breaks.
• UK divergence: The UK’s own EMIR reporting framework is taking a slightly different path. While broadly aligned, differences in field definitions and timing mean that dual-reporting firms must manage two subtly different schemas.
In the United States, reporting expectations continue to evolve across multiple regulatory tracks:
• Consolidated Audit Trail (CAT): FINRA and the SEC continue to expand the data captured by CAT, which now covers the full lifecycle of equities and options orders. Accuracy and timeliness remain under close scrutiny, and firms have been fined for persistent reporting failures.
• Blue sheets: While Blue Sheet reporting has been in place for years, recent enforcement actions – including fines against major firms like UBS and Robinhood – have highlighted the risks of data errors and submission delays. Regulators are increasingly using Blue Sheet data as a cross-check against other surveillance feeds.
• TRACE (Trade Reporting and Compliance Engine): For fixed income markets, TRACE continues to be the primary reporting mechanism. With the addition of new asset classes and reporting windows, firms must ensure their systems can handle increasing volumes and complexity.
In Asia-Pacific, reporting frameworks vary significantly by jurisdiction, but the trend is clearly toward greater alignment with international standards.
• MAS (Singapore): MAS has been updating its OTC derivatives reporting requirements, bringing them closer to the CPMI-IOSCO framework. Firms operating in Singapore should expect more detailed data submissions and more rigorous reconciliation expectations.
• ASIC (Australia): ASIC’s derivatives reporting rules are also evolving, with a focus on improving data quality and consistency. The regulator has flagged specific areas of concern, including entity identification and lifecycle event reporting.
• SFC/HKMA (Hong Kong): Hong Kong has been progressively enhancing its OTC derivatives reporting requirements, including new fields and validation rules. Firms should also be aware of upcoming changes to the reporting of securities transactions as part of a broader market infrastructure review.
Across all jurisdictions, several themes are emerging:
1. Data quality is no longer optional: Regulators are investing in analytics capabilities that can detect anomalies, inconsistencies, and gaps in reported data. The expectation is that firms will get it right the first time – and fix it fast if they don’t.
2. Interoperability is critical: As firms navigate multiple reporting regimes, the ability to manage data in a standardised, flexible way becomes essential. Firms that rely on fragmented, siloed systems will struggle to keep up.
3. Reporting and surveillance are converging: Regulators increasingly view reporting data as a surveillance tool. The lines between transaction reporting and market abuse detection are blurring, meaning that compliance teams must think holistically about how data is captured, validated, and used.
4. Vendor and technology risk is in focus: Regulators are paying more attention to how firms select, manage, and oversee the technology and third-party providers they use for reporting. Governance of RegTech is becoming a compliance topic in its own right.
Navigating this landscape requires robust, flexible, and accurate reporting infrastructure. eflow’s regulatory reporting solutions are designed to support firms across jurisdictions, covering EMIR, MiFIR, and more. Our platform helps firms reduce reporting errors, streamline remediation, and maintain compliance in an increasingly demanding environment.
To learn more about how we can support your regulatory reporting needs, get in touch.
