EU regulators haven’t paused on reporting quality

As we’ve been discussing for almost 12 months now, the EU regulatory reporting change agenda has, for the first time in several years, largely paused while the European Securities and Markets Authority (ESMA) considers the feedback received from its Call for Evidence (June 2025) on simplifying financial reporting. Until that process concludes, the legislative schedule for MiFID II transaction reporting and related frameworks has stalled.

Some reporting firms may have drawn the wrong conclusion from this pause by thinking that if ESMA has slowed down, regulators across Europe might focus their attention elsewhere and ease their demands for high-quality reporting data. Recent publications from two mainland European regulators suggest otherwise.

AMF and CSSF both signal continued focus on reporting data quality

The Autorité des marchés financiers (AMF) in France and the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg have each released detailed papers outlining how they monitor MiFID II transaction reporting, the common reporting issues they continue to find and what they expect from supervised firms.

The timing is notable and reinforces that national competent authorities (NCAs) are not standing down while the legislative picture clears. 

CSSF: systematic testing and quarterly remediation feedback

The CSSF’s January 2026 press release outlines its ongoing transaction reporting quality testing. As of 1 January 2026, 105 Luxembourg firms are in scope, submitting nearly 24 million reports in 2025. The CSSF applies standardised tests aligned with NCAs and ESMA, alongside its own quarterly analytical summaries (running since 2022), which highlight data inconsistencies firms are expected to investigate and fix.

Key focus areas include instrument price anomalies, branch field errors affecting NCA routing, inconsistent INTC account MIC usage, cross-checks with Suspicious Transaction and Order Reports (STORs), and reconciliation with Luxembourg Stock Exchange order book data. The CSSF also emphasises that transaction data is increasingly used beyond market abuse monitoring, including for single volume cap calculations, raising the importance of accuracy across all fields.

AMF: reporting controls named as a 2026 supervisory priority

France’s AMF has explicitly identified data-quality frameworks and reporting controls as a 2026 supervisory priority. While regulators often highlight data quality issues, it is less common to see formal focus on the underlying processes that produce the data. This suggests that AMF scrutiny may extend beyond outputs to firms’ internal controls.

Meanwhile some firms with dual reporting obligations in both the UK and EU may have been distracted by the reporting “revolution” (simplification rather than deregulation) currently being contemplated by the UK’s Financial Conduct Authority.

What this means for reporting firms

The message from continental Europe is clear: while the legislative process may be sitting in the sidings, regulators are still actively using, monitoring and challenging firms on the quality of their reported data.

• Regulatory reporting data quality remains a supervisory priority. Regulators continue to emphasise the accuracy, completeness and reliability across MiFID II transaction reporting submissions.
• Transaction reports are actively monitored.  Validation checks and analytical reviews are running on submitted data on a recurring basis, not just when something has gone wrong.
• Supervisors conduct systematic data-quality testing, analysing key reporting fields such as instrument identifiers, prices, client identifiers and trading-venue information to detect anomalies.
• Firms receive regulatory feedback on potential issues. The CSSF distributes quarterly analytical summaries highlighting potential reporting errors that firms are expected to investigate and remediate.
• Regulators cross-check datasets. Transaction reports are compared with other supervisory data sources such as STORs and trading-venue data to identify inconsistencies.
• Proactive remediation is expected. Firms are expected to identify and correct reporting issues themselves rather than waiting for regulators to highlight them.
• Regulatory reporting controls are under scrutiny. The AMF has specifically identified data-quality frameworks and reporting controls as an area of supervisory focus for market intermediaries.
• High-quality reporting underpins market supervision. Accurate data is essential for market abuse detection, trading-volume monitoring and broader market oversight.
• The current MiFIR reporting framework remains in force. Despite reform being paused, firms must continue to comply fully with existing reporting obligations without interruption.

The window to act

It’s clear that even though the regulatory reform agenda has slowed temporarily, supervisory expectations around reporting quality have not.

For firms subject to transaction reporting, the time allowed by the pause in the change agenda should be used wisely: this is a practical opportunity to ensure that assurance and controls, monitoring and remediation processes are working as intended.

The rules, they are going to be “a-changin”, and it’s always easier to navigate change from solid ground than from shifting sand. 

For a conversation about your transaction reporting data quality or a demo of our assurance platform, please get in touch.