The European Association of CCP Clearing Houses (EACH) has responded to ESMA’s call for evidence on simplifying financial transaction reporting. Its message is clear: today’s overlapping rules create unnecessary costs and confusion, and reforms are needed, but simplification must not come at the expense of supervisory oversight.
According to EACH, a single derivatives trade may be reported multiple times under EMIR, MiFIR, SFTR, MAR and REMIT. In the case of energy derivatives, the same transaction could appear in reports as many as five times. The association argues this adds cost without improving data quality, as supervisors receive fragmented and sometimes inconsistent information.
Frequent rule changes and dual-sided reporting, where both parties report the same trade, add further strain. EACH warns that this undermines efficiency while raising operational risks for post-trade infrastructures and their participants.
Options on the table
EACH discusses several reform paths. One short-term solution is to reduce duplication by aligning EMIR and MiFIR requirements and allowing for single-sided reporting. In the longer term, the association supports exploring a “report once” model across all regimes, built on harmonised templates and stronger coordination among authorities.
At the same time, EACH stresses that data necessary for monitoring systemic risk, detecting abuse and ensuring transparency must remain intact. Reporting may be simplified, but the depth of information regulators receive should not be diminished.
A phased approach
Given the complexity of a full “report once” system, EACH recommends a phased implementation. Removing overlaps and aligning formats would deliver quick relief, while gradual steps could pave the way toward broader integration.
