ESMA sets out proposals for integrated funds data reporting

Funds reporting in the asset management sector is currently subject to significant fragmentation due to the coexistence of several reporting regimes at national and European level, resulting in high compliance burdens and inconsistent data definitions. Following a discussion paper last June, ESMA has now published a report setting out proposals which seeks to move away from this fragmented approach towards a streamlined, “report once, use many times” reporting system, centred on a common and single reporting template and a centralised EU data hub, with relevant authorities able to access only the data required to meet their respective activities and powers.

A single integrated reporting template

In the report, published on 4 May 2026, ESMA proposes a new single, modular and dynamic reporting template, supported by a common regulatory data dictionary, aligned data semantics, centralised validation, data sharing and common analytics. The model seeks to harmonise reporting and reduce duplication across AIFMD, UCITS, national supervisory and certain aspects of statistical reporting frameworks, while maintaining proportionality across fund sizes, strategies and risk profiles. Under the framework existing reporting templates and data fields would be systematically reviewed and streamlined to remove duplications and low-value data items before integration.

To address the diversity within the fund industry, the reporting framework would include core modules (covering standard information relevant to all funds), which would be complemented by additional dedicated modules specifically tailored to reflect fund types with distinct fund attributes (such as use of leverage) or specific statistical or supervisory requirements or needs (such as thematic modules to address specific supervisory concerns, e.g. portfolio holdings). As a result, the envisaged framework and modular approach will account for differences in structural features and risk profiles of different funds, with ESMA calling out the example of real estate funds compared to liquid security funds. 

In line with the principle of proportionality, ESMA notes that simpler funds would be subject to fewer reporting modules than more complex funds, and there may be different reporting frequencies for different modules. 

The framework will also allow event-based modules, activated only when specific supervisory-relevant events occur, to enable timely and harmonised reporting without recurring obligations. This may include “crisis response modules” in times of market stress. 

ESMA also indicates that this modular system would be adaptable to future reporting changes, when new modules could be developed to capture additional requirements without disrupting the overall reporting framework. 

Any ad-hoc reporting from national requests should remain exceptional and proportionate. 

The full set of data fields for each module will be defined by forthcoming work on RTS and ITS under AIFMD and UCITS, with ESMA indicating that there will be a focus on data that is valuable for supervisory, financial stability or statistical purposes, or to identify, monitor or assesses material risks. 

A centralised EU data hub 

The proposed operating model would keep data collection at national level but organise validation, storage and analytics through a centralised EU data hub. 

Under this proposed structure, reporting entities will be required to submit a single, comprehensive integrated report (encompassing all supervisory and statistical data elements from AIFMD, UCITS, MMFR and relevant statistical frameworks) to a single designated national authority, which will act as the sale national front-end collection point. 

ESMA says this should support a “report once, use many times” approach, enabling supervisors and other authorities to access and reuse data rather than requesting similar information through separate channels. This will also contribute further to burden reduction by limiting duplicative data requests. Furthermore, given that investment funds increasingly operate across multiple jurisdictions, often managed in one Member State but marketed in several others, a common data hub would facilitate cross-border analysis. Additionally, it would enable comparative peer analysis, allowing local authorities to benchmark the behaviour and risk profiles of domestic funds against their EU peers to identify specific national trends.

A two-phase implementation approach

To ensure continuity of supervisory data monitoring and to minimise disruption, ESMA recommends implementation to be introduced under two phases:

• The first phase will focus on consolidating the AIFMD and UCITS supervisory reporting requirements. This initial phase will provide the necessary time to develop and implement the underlying infrastructure required to support the new reporting framework (subject to relevant funding, which will need to be substantial) , prior to its technical formalisation at a later stage. This phase will include work on defining and aligning data fields and business concepts for the development of a data dictionary (with ESMA’s report setting out principles for the dictionary in terms of semantics and syntax, including the use of standard identifiers to ensure consistencies). ESMA highlights that a key priority for the proper functioning of this first phase of the project is the development of enhanced data-sharing agreements between supervisory and statistical authorities and will be engaging with the European Central Bank to assess and put in place the necessary arrangements to share data collected.

• The second phase would expand the integrated framework to encompass MMFR, statistical reporting requirements, and potentially other reporting obligations applicable to the fund sector.

Next steps

Although ESMA acknowledges some limitations in Level 1 that impact the ability to move to the single reporting framework, ESMA does not propose Level 1 changes at this stage but wants to move forward towards the integrated reporting framework by developing Level 2 and 3. 

ESMA aims to consult on draft RTS and ITS for the revised AIFMD and UCITS reporting framework “later in 2026”, with a final report due by April 2027. 

In parallel, ESMA intends to launch the development of the reporting IT system, subject to the availability of funding, in 2027, with go-live of reporting expected in H1 2029 at the earliest. 

Existing reporting templates will remain in force until the integrated framework is fully implemented, tested and proven sufficiently robust. 

ESMA’s final report is available here.

ESMA’s press release is available here.

Read our previous blog post on ESMA’s interim update on transaction reporting reform which was published at the same time as part of ESMA’s broader simplification and burden reduction agenda.