ISDA has submitted to the European Securities and Markets Authority (ESMA) an analysis of the costs of regulatory reporting, which proposes where savings can be made most effectively.

This document supplements the recent response submitted by ISDA, the Association for Financial Markets in Europe, FIA and the Global FX Division of the Global Financial Markets Association to ESMA’s call for evidence on a comprehensive approach for the simplification of financial transaction reporting. The new analysis and proposals reflected in this supplementary document were developed based on member feedback to a questionnaire carried out by ISDA. All answers have been anonymized and aggregated.

The responses supported many of the arguments put forward in the original response, with the most impactful cost saving identified as the delineation by instrument (OTC derivatives under the European Market Infrastructure Regulation and exchange-traded derivatives under the Markets in Financial Instruments Regulation) as proposed under Option 1a. There was also strong support for single-sided reporting and the removal of pairing and matching requirements.

ISDA developed this analysis for ESMA’s consideration in drafting the final report following the call for evidence.