ESMA Doubles Down on Data Quality

The European Securities and Markets Authority (ESMA) released updates to its Data Quality Engagement Frameworks (DQEFs) offering firms rare visibility into how National Competent Authorities (NCAs) and ESMA assess the quality of reported data across key regulatory regimes. 

These updates are more than just technical guidance, they are essential for firms in scope, including those reporting under regulations, including:  

• Markets in Financial Instruments Regulation (EU) No 600/2014 (MiFIR) 
• Regulation (EU) 2019/834 amending the European Market Infrastructure Regulation (EMIR) (EU) No 648/2012 (EMIR Refit) 
• Securities Financing Transactions Regulation (EU) 2015/2365 (SFTR) 
• Alternative Investment Fund Managers Directive 2011/61/EU (AIFMD) 

They signal a clear regulatory expectation that data quality controls must be robust, transparent, and defensible. With this increased transparency, now is the time to take a closer look at your firm’s processes and controls. 

What’s in the Update? 

The expanded ESMA library includes detailed DQEF documentation for: 

• MiFIR Article 26 (transaction reporting) 
• FIRDS (instrument reference data) 
• EMIR Refit 
• SFTR  
• Money market funds 
• Short selling 
• AIFMD 

These frameworks reveal how regulators assess completeness, accuracy, and timeliness, and they highlight specific metrics used to benchmark firms’ submissions, often in direct comparison to peer groups. Poor data quality may be just as likely to trigger regulatory attention as a missed filing deadline or compliance breach. 

Why This Matters Now 

The release forms part of a broader supervisory trend: regulatory reporting is no longer just a back-office process—it’s a core compliance obligation. Errors, omissions, or inconsistencies in reporting data are increasingly viewed as indicators of deeper governance or operational failings. 

Firms that are unprepared may find themselves subject to regulatory follow-up, or worse—caught flat-footed during an exam or data quality sweep. 

Our Guidance 

Start by reviewing the latest DQEF documentation and asking: 

• How does our current reporting compare to ESMA’s benchmarks? 
• Are our validations, reconciliations, and governance processes sufficient? 
• Do we have the technology and expertise to respond quickly if issues are identified? 

If your answers are uncertain—or the frameworks raise new questions—we’re here to help. 

How We Help 

Our advisory and technology solutions are designed to help you meet heightened expectations with confidence: 

• EMIR Refit: Our teams provide reporting gap assessments and deep-dive reconciliations. Automated tools help validate trade data, counterparty identifiers, and valuation submissions to ensure accuracy and compliance. 

• MiFIR Transaction Reporting: Through our ARRMA (ACA Regulatory Reporting Monitoring & Assurance) platform, firms can perform detailed reconciliations and health checks on transaction data, testing completeness, accuracy, and alignment with regulatory rules before issues arise. 

• Market Abuse Surveillance: Enhance trade surveillance and regulatory compliance with automated detection of insider trading and market manipulation, customisable algorithms to reduce false positives, and integrated forensic testing tools—all within ACA’s ComplianceAlpha^® platform. 

Whether you’re dealing with field-level validation issues, submission error rates, or counterparty data mismatches, our cross-regulatory expertise and scalable tech can help identify gaps and mitigate risk. 

Get in touch to book a free ARRMA review and learn how we can support your firm’s efforts to align with ESMA and NCA expectations under EMIR and MiFIR, and simplify your trade surveillance.