427. On 10 July 2017 ESMA submitted to the European Commission amendments to the RTS on data access regarding the publication of aggregate position data by trade repositories pursuant to Article 81 of Regulation (EU) No 648/2012.

428. ESMA proposed to amend the aforementioned RTS as its practical implementation highlighted particular situations where improvements could be made to facilitate a better market-wide aggregation and comparison of the data published by trade repositories. In addition, ESMA set out additional requirements, in line with the mandate, to better specify and enhance the data made publicly available by trade repositories and to allow the publication of certain aggregate figures that are required by EU legislations such as MiFID II and the Benchmarks Regulation.

429. In order to ensure that the end users are able to compare the aggregate position data published by the TRs, ESMA proposed, in the draft amendments to the RTS, the general rules for making the data publicly available as well as the specific rules to perform aggregations at the level of the individual TRs by defining the following aspects:

a. the frequency and timeliness of publication;

b. the general technical aspects of aggregation for the purpose of publication;

c. the details of aggregations for the purpose of benchmarks' thresholds; and

d. the details of aggregations for the purpose of trading size of commodity derivatives.