255. The current definition of 'Reporting timestamp' is already aligned to the CDE guidance, therefore no change was necessary. None of the respondents to the Consultation Paper advocated for changing the definition.

256. However, one respondent commented that the reporting timestamp should not be included in the inbound message from the report submitting entity as it is possible that a report submitting entity could populate this value with a timestamp that is significantly different from the actual time they made the submission, avoiding the potential control-related nature of this information. The respondent proposed that instead, the TRs should create and record the reporting timestamp based on the time the submission was received. In this regard ESMA reiterates that reporting timestamp is one of the critical data elements that, as per the CDE guidance, should be reported to TRs.