FESE response to ESMA consultation on the review of RTS 22 and 24

FESE advocates for a simplified transaction reporting regime that upholds market integrity and supervision without imposing unnecessary additional requirements on supervised entities. In this regard, we also encourage consideration of key areas where a harmonised approach to both on-venue and off-venue transactions would enhance consistent market surveillance, as well as recognition of the challenges and costs trading venues face in collecting external data.

Furthermore, FESE appreciates efforts to streamline reporting requirements across regulations such as MiFIR, EMIR, and SFTR, particularly where greater consistency improves comparability and clarity. We strongly support maintaining alignment between reporting obligations under RTS 24 and RTS 22, as this is crucial for ensuring data consistency and preventing a decline in data quality.

For more details on our specific recommendations regarding ESMA’s proposals on RTS 22 and RTS 24, please refer to our response to the ESMA consultation.