What happened
The European Securities and Markets Authority (ESMA) has published its final report on the simplification of transaction reporting, setting out a clear path towards a ‘Report Once’ approach. ESMA Chair Verena Ross framed transaction reporting as central to market transparency, risk monitoring and detecting market abuse, while acknowledging that fragmentation has produced duplication, inconsistent requirements and higher costs for both market participants and authorities.
At the core of the proposal is a single integrated transaction reporting framework across MiFIR, EMIR and SFTR, built on a common modular structure. Under this model, transaction data would be reported once and then reused across authorities and supervisory mandates, reducing duplication while preserving the information supervisors need. The report is a key deliverable under ESMA’s broader Simplification and Burden Reduction (SBR) initiative.
The numbers behind the reform
ESMA’s cost-benefit analysis, informed by a study involving market participants, indicates the ‘report once’ scenario could deliver:
- Annual net savings of €250 million to €1.0 billion;
- A reduction in recurring costs of around 22%–24%;
- 10-year discounted cumulative net benefits of €1.2 billion to €4.9 billion.
Implementation costs are expected to be recovered within three to four years, after which efficiency gains would accrue on a sustained basis. ESMA identifies the main cost drivers as frequent and unsynchronised regulatory changes, duplication across frameworks and channels, and dual-sided reporting with its associated reconciliation burden.
What it means in practice
It is important to be precise: this reform targets the traditional markets reporting regimes — MiFIR, EMIR and SFTR — not MiCA directly. However, the implications reach well beyond conventional trading firms.
Many crypto businesses now operate across multiple regulatory perimeters. A firm dealing in tokenised securities or crypto-asset instruments that qualify as financial instruments can fall within MiFIR scope; those active in derivatives or securities financing transactions engage EMIR and SFTR. For these operators, the duplication and reconciliation costs ESMA describes are a lived reality, and a move to a modular ‘report once’ architecture would materially lighten the operational and compliance load.
Equally significant is the direction of travel. The SBR initiative reflects ESMA’s stated appetite to reduce reporting complexity and improve data usability across the EU framework. For anyone building a compliance operating model today, designing around a future of consolidated, standardised, reusable reporting — rather than siloed, framework-by-framework submissions — is the prudent bet.
Near-term measures worth noting
Alongside the long-term reform, ESMA proposes intermediate measures for more immediate relief:
- Expanding the use of delegated reporting arrangements;
- Streamlining intragroup exemption procedures;
- Targeted ESMA-level adjustments to reduce low-value or duplicative reporting requirements.
These are designed to cut costs now while remaining compatible with the future integrated framework — useful for group structures and firms already carrying reconciliation overhead.
Next steps for applicants and licensees
ESMA will now engage with EU institutions on its recommendations. The integrated ‘report once’ approach will require targeted legislative changes, phased implementation, and an inclusive dialogue with industry technical experts to develop reporting templates, data standards and streamlined infrastructure. In short, this is the start of a multi-year process, not an immediate rulebook change.
Practical considerations for executives:
- Map where your current or planned activities touch MiFIR, EMIR or SFTR, not only MiCA, so you understand your true reporting footprint.
- Build reporting systems with modular, reusable data structures rather than one-off framework pipelines.
- Assess whether delegated reporting or intragroup exemptions can reduce your near-term costs.
- Consider contributing to the industry technical dialogue on templates and data standards as reform develops.
If you are scoping authorisation and want your compliance architecture aligned with where EU reporting is heading, our team can help you structure a crypto / VASP license in European Union around a future-proofed reporting model.
