ESMA’s 2024 Annual Report: Data Quality Progress and Recent MiFIR Review Developments

ESMA’s 2024 Annual Report, released in June, provides a wide ranging overview of the European regulator’s activities across its broad mandate. While the 84-page document touches on numerous regulatory initiatives, the updates on transaction and trade reporting frameworks provide useful insights for reporting firms.  

Data Quality Indicator Dashboards  

The report highlights ESMA’s implementation of data quality indicator (DQI) dashboards, now accessible to National Competent Authorities (NCAs) via ESMA’s data platform, for both MiFIR transaction reporting and EMIR trade reporting.  

The new framework establishes clear accountability: reporting entity issues go to relevant NCAs, while Data Reporting Service Provider (DRSP) problems are handled directly by ESMA. While in theory the DQIs sound like an improvement in supervisory tools, as we know, the real test will be whether they translate into meaningful improvements in data quality. 

MiFIR Developments Overshadowed by Strategic Pause 

ESMA’s data strategy implementation focused on “optimising financial market data while reducing regulatory burden” through reusing transaction data to eliminate duplications. The migration to ESMA’s new data platform allowed wider use of MiFIR transaction data for applications like monitoring European carbon market integrity.  

The most significant development came after the Annual Report’s publication when ESMA announced that the MiFIR Review is being put on hold while it conducts a Call for Evidence “to gather feedback on opportunities to simplify, better integrate and streamline supervisory reporting.” This pause affects existing requirements under transaction reporting (RTS 22), order data (RTS 24), and reference data (RTS 23). 

The Call for Evidence deadline is September 19, with ESMA’s final report due by early 2026.  

EMIR: Modest Improvements Amid Complexity 

The report also highlights improvements in EMIR reporting data quality, supported by ESMA’s peer review follow-up. However, these improvements should be seen in perspective, coming after many years of well-known data quality problems that have made effective supervision difficult. 

ESMA’s Trade Repository supervision during the EMIR Refit implementation was more successful, which the regulator attributes to intensive pre-implementation engagement.  

Broader Regulatory Pressures 

Beyond reporting frameworks, the Annual Report reveals an organisation struggling with an expanded mandate and limited resources. ESMA admits it has had to move staff and resources to different areas due to new responsibilities without the additional funding. 

The report also illustrates ESMA’s increasingly broad mandate. This shows regulatory ambition, but it also highlights how difficult it is to maintain focus and expertise when covering so many complex areas. 

Evolution, Not Revolution 

The developments in MiFIR and EMIR reporting represent gradual improvements rather than fundamental reforms to regulatory reporting. Better data quality tools and clearer operational guidance are welcome, but they address symptoms rather than the underlying framework and complexity of rules. 

The pause of the MiFIR Review, while giving breathing space for firms, acknowledges that the current approach may be overly burdensome. For firms, this provides an opportunity to influence the direction of the reporting framework but obviously extends the uncertainty about long-term requirements. ESMA’s growing focus on data and enhanced supervisory powers suggests more intensive oversight could be just around the corner.