ESMA seeks input on how to integrate funds reporting of supervisory data

Funds reporting in the asset management sector is now subject to significant fragmentation due to the coexistence of several reporting regimes at national and European level, resulting in high compliance burdens.  In light of this, on 23 June 2025, ESMA published a discussion paper seeking input on how to integrate funds reporting of supervisory data, with the goal of reducing the reporting burden for market participants.  The paper closes for comments on 21 September 2025.

The report presents a stock take of the current state of asset managers’ reporting obligations and assesses the overlaps and inconsistencies between the reporting frameworks.  It then presents several options to further integrate the reporting obligations for fund managers under different regimes, alongside 5 main priorities.

Options 

The report sets out 3 integrated reporting options for discussion:

• Option IR1: Integrated reporting - Multiple reporting obligations with reuse of data: setting up a coherent framework across multiple EU reporting regimes as a holistic view composed of multiple datasets, so that data submitted once can serve multiple oversight purposes.
• Option IR2: Full integrated reporting framework: creating a new single EU-wide reporting structure to replace all existing EU and national-level reporting obligations under the AIFMD, UCITS Directive, MMFR, and statistical frameworks. The objective would be to streamline both supervisory and statistical data collection and significantly reduce the reporting burden for fund managers and possibly for authorities as well.
• Option IR3: Full integrated reporting framework including specific national reporting requirements: building upon the modular approach of Option IR2 by introducing an additional layer of flexibility for NCAs. Under this option, the data model would be designed to accommodate national-specific reporting fields, enabling authorities to collect information necessary for national supervisory and statistical priorities without disrupting the overall structure of the integrated framework. 

Priorities

ESMA sets out the following as the key priorities guiding the path toward greater integration – with a focus always on proportionality and operational feasibility:

• Concentrating on elements with high added-value:  The objective of the integrated template is not to introduce new data fields but to rationalise existing reporting requirements by focusing on elements that offer high added value. This means prioritising data that is critical for achieving statistical and supervisory objectives, risk assessment, market surveillance, and enhancing investor protection

• The choice of data semantics: recognising that divergences (e.g. varying definitions, classifications, labels, and interpretations of the same data points across multiple regulatory frameworks)  are creating inefficiencies, inconsistencies, and an increased reporting burden for fund managers

• Different options for reporting flows and data sharing arrangements: exploring whether a single collecting authority, or via a centralised reporting system might be feasible

• Different options of reporting formats and systems: pushing forward options to harmonize where possible

• The choice of reporting frequency

Next Steps 

ESMA will consider the feedback it receives to this discussion paper during the course of Q4 2025 and expects to submit a report on the development of an integrated collection of supervisory data to the European Commission in Q2 2026 (under Article 69a of AIFMD and Article 20b of UCITS Directive (as amended), ESMA is mandated to submit this report to the European Commission by 16 April 2026).

Call for Evidence for the simplification of transaction reporting 

In parallel, ESMA has published a call for evidence on how transaction reporting regimes under MiFIR, EMIR and SFTR (and potentially other regimes) could be streamlined or simplified. Read our note, ‘ESMA seeks views on comprehensive review of transaction reporting regimes’ on our Knowledge Portal for more detail.