ESMA's 2024 Data Quality Report: What You Need to Know

In April, the European Securities and Markets Authority (ESMA) published its 2024 Report on Quality and Use of Data (5th edition). The report covers data disclosed under various regulations within ESMA’s remit, including the European Market Infrastructure Regulation (EMIR), the Securities Financing Transactions Regulation (SFTR), and the Markets in Financial Instruments Regulation (MiFIR). 

The addition of ESEF and short-selling data to the 2024 report highlights the increasing use of data by authorities to support key objectives such as financial stability, orderly markets, and market integrity. 

Key Findings and Areas of Focus From the Report 

• EMIR Refit Impact on Data Quality: The report notes improvements in rejection rates and the upgrading of legacy derivatives, with only 2% of the trade base not upgraded to new standards as of February 2025. 
• EMIR Data Quality Indicator (DQI) Performance: Rates of incorrect Entity Responsible for Reporting (ERR) have reduced and remain below threshold. However, other DQIs remain too high, exceeding the 5% threshold, with most between 10% and 20%. 
• Enhanced Focus on SFTR Data Quality: The report addresses the need for improved quality in SFTR data, acknowledging that “large margins of improvement” remain. 
• DQIs for SFTR: ESMA finalised its DQI approach for SFTR, following the successful rollout for EMIR, indicating this will be a growing area of focus in future. 
• SFTR DQI Performance: As with EMIR, incorrect ERR rates remain below threshold, but other indicators still exceed acceptable levels – some reaching 10-35% – despite notable improvement from previous years. 
• Enhanced Cooperation With BaFin: ESMA and BaFin are working together through “periodic engagement” to improve data quality. 
• Improved Data Quality Through Engagement Frameworks: The report highlights cases where structured engagement frameworks have led to measurable improvements in data quality. 
• Transparency and Support for External Users: A new annex provides methodologies for calculating data quality indicators, along with code for web-scraping data from regulatory authorities, aiming to enhance transparency and support. 
• Increased Use of Transaction Data by Regulatory Authorities: The report underlines growing use of transaction data for market monitoring, supervision, enforcement, and policymaking. 
• Data Governance Frameworks: The report reinforces the importance of strong governance to ensure data accuracy, completeness, and relevance. 
• Data Quality Benchmarking: Benchmarking remains essential for measuring and improving data quality. 

When reviewing the findings, it’s important to remember that data quality is now a key concern for all firms with a reporting obligation. Historically, buyside firms that delegated their reporting were only responsible for ensuring timely submission of trades to a Trade Repository (TR). However, following the implementation of EMIR Refit, delegating firms are now also responsible for the integrity and quality of the data being submitted. 

Trade Reporting Analytics – How We Can Help 

With ESMA – and other regulators – placing greater scrutiny on data quality than ever before, the ability to access, evaluate, and respond to detailed insights on reporting behaviour is critical. 

In response to strong demand for analytical tools from its global client base, DTCC launched its Trade Reporting Analytics service just over a year ago to provide clients of the Global Trade Repository (GTR) with increased transparency into data quality across their derivatives trade reporting submissions. Take-up has been particularly strong in Europe, especially among buyside firms, reflecting the industry’s heightened focus on data quality. 

With no integration required, clients can access comprehensive, near real-time insights across their globally reported data. This helps them identify and resolve specific reporting challenges and benchmark performance against peers. Insights include the EMIR Errors & Omissions dashboard and other key Data Quality Indicators referenced in the report. 

As global regulatory rewrites continue – with the UK EMIR Refit transition just concluded, JFSA Phase 3 on the horizon, and updates from HKMA and Canada expected later this year – DTCC’s product team is continuously planning ahead to enhance the service and maximise value for clients. Following the 2024 report’s emphasis on SFTR data quality challenges, expanding our analytics for SFTR reporting will be a top priority on this year’s roadmap.