The Swedish Securities Markets Association (SSMA) has responded to ESMA Consultation regarding EMIR 7d reporting

EMIR 3 introduced Article 7d, which mandates ESMA to develop draft regulatory technical standards (RTS) and implementing technical standards (ITS). These standards shall specify the content and format of clearing members and clients annual reporting on their activities with recognized third-country central counterparties (TC-CCPs). ESMA is now seeking comments on its proposed technical standards for the implementation of the reporting requirement. In line with the Union’s agenda for simplification and reducing the regulatory burden, the proposed framework aims to reuse, to the greatest extent possible, information already available through existing reporting channels and to limit new reporting requirements to data that ESMA or competent authorities cannot otherwise access.

The SSMA’s opinion:

• SSMA agrees that most of the necessary information is already reported under EMIR, SFTR, MiFIR, and the CCP regulations.
• The supplementary reporting under Article 7d is assessed to provide limited supervisory benefit but entail significant costs, system development, and recurring compliance work.
• ESMA should therefore limit the requirements to an absolute minimum, avoid duplicate reporting, and clearly justify each additional data field. If the benefits continue to be assessed as low, ESMA should inform the European Commission ahead of a future review of EMIR.

Read the ESMA consultation on EMIR 7d reporting – October 2026