80. Article 9(6) of EMIR, as amended by REFIT, provides ESMA with an empowerment to specify the data standards and formats of the reports with the objective to ensure a uniform application of the reporting obligation. In developing the technical standards, ESMA shall take into account the international developments and standards and their consistency with the reporting requirements under Article 26 of MiFIR (transaction reporting) and Article 4 of SFTR.

81. In the Consultation Paper, ESMA proposed to use ISO 20022 as a single standard for EMIR reporting, to be used by all reporting counterparties in addition to TRs. ISO 20022 is currently used for other regulatory reporting regimes and has widespread acceptance in the financial industry. ESMA considers ISO 20022 to provide open and transparent standards, and to cater for a robust governance framework for EMIR reporting.

82. Furthermore, in order to reduce the prevailing issues in reporting to TRs, such as elevated rejection rates, non-harmonised data transformations, complex processing and the difficulty in porting from one TR to another, ESMA proposed to introduce a harmonised XML schema for reporting to TRs. A common XML schema enables also to embed some data quality validations in the schema, allowing for first verification of data at the point of report generation.