When I look back on 2025, what stands out most is not the size of the regulatory wave we all rode - but the fact that our infrastructure, our people, and our clients surfed it together and finished the year stronger. After the seismic go‑lives of EMIR REFIT in the EU (April 2024) and the UK (September 30, 2024), 2025 was the first true “run‑rate” year under the new data model, message formats, and validation logic. Our job at REGIS‑TR was clear: make the new world feel routine.
By year‑end, our next‑generation, modular REFIT platform was not just live—it was fully stabilised and operating at scale. Each month, REGIS‑TR SA processed around 500 million EMIR records, plus ~7.5 million FinfraG** and ~7.5 million SFTR records, while REGIS‑TR UK handled ~70 million EMIR UK records. Those aren’t just big numbers; they reflect dependable throughput, consistent validations, and timely routing to National Competent Authorities across Europe - exactly what a market‑critical utility must deliver.
We also retained clear market leadership: more than 50% of EU EMIR reporting flows passed through REGIS‑TR in 2025—supported by a client community of 1,500–1,600 firms in 40+ countries. Leadership is a privilege, but in regulatory reporting it’s also a responsibility: we have to keep the pipes clean, secure, and future‑proof while the regulatory design keeps evolving.
What the numbers really say
* >50% EU EMIR market share; ~500m EMIR records/month in the EU — scale matters, but only when paired with stability and data integrity. Our platform upgrades reached full maturity in 2025, giving us both capacity headroom and the fine‑grained controls REFIT requires.
* 1,500–1,600 clients, 40+ countries — a breadth of user types that demands flexibility without compromise. We support global banks, buy‑side firms, clearing members, and corporates with a consistent, robust set of tools.
* Multi‑regime delivery (EMIR EU, EMIR UK, SFTR, FinfraG) — each regime reflects regulatory nuance. Our UK entity demonstrated that we can support divergence without compromising consistency or control.
What enabled us to do that? Three pillars:
1. A modular, resilient platform built for change. We designed our REFIT stack to adapt quickly to new rules and growing volumes, with advanced analytics embedded for proactive data‑quality monitoring. That design choice paid off as firms moved from first submissions to sustained, high‑fidelity reporting.
2. Pragmatic tools that meet firms where they are. The shift to ISO 20022 XML could have been a shock to established back‑office processes. To take friction out, we introduced a CSV‑to‑XML converter, letting clients keep familiar file formats while conforming to the new standard—reducing re‑engineering effort and error rates along the way.
3. Actionable insight, not just submission. Our data‑quality and performance services gave clients clear views on rejection drivers, reconciliation outcomes, and peer‑group benchmarks—so remediation could be targeted and measurable. This led to steady improvements in matching and fewer preventable rejections through the year.
ESMA’s Call for Evidence: A Turning Point for EU Reporting Simplification
ESMA’s June 2025 Call for Evidence marked one of the most significant shifts in EU reporting policy, signalling a move toward a more holistic and simplified framework. The CfE recognised long‑standing industry concerns that EMIR, MiFIR and SFTR have evolved into overlapping regimes, often forcing firms to report the same economic event multiple times with minor variations. By exploring options such as removing duplications, redefining reporting boundaries by instrument or event type, and even considering a “Report Once” model, ESMA opened the door to genuine structural reform rather than incremental adjustments.
This broader reassessment quickly reshaped the trajectory of MiFIR. The proposed RTS 22 changes—expanding derivative scope, almost doubling reportable fields, and shifting from XML to JSON—risked adding complexity precisely when the EU was seeking simplification. While alignment with EMIR/SFTR remains directionally positive, industry feedback highlighted that format and scope changes of this scale, absent cross‑regime harmonisation, would impose disproportionate cost without clear data‑quality benefits. Against this backdrop, the European Commission’s decision to pause the MiFIR amendment process reflected not a retreat but a recognition that MiFIR must be reviewed in sync with ESMA’s wider simplification effort. The pause therefore enables the EU to “fix the framework” rather than merely “change the form” - a more coherent outcome for both firms and supervisors.
Keeping the industry aligned through divergence
As all of this played out, we continued supporting firms navigating EU–UK divergence, where REFIT differences became fully operational realities in 2025—from validations to counterparty logic to reconciliation expectations. Our stance remains unchanged: harmonisation of outcomes matters more than identical rulebooks. With the right combination of tooling, diagnostics, and data‑quality metrics, firms can meet both EU and UK requirements without duplicative effort or inconsistent reporting. And as ESMA’s Call for Evidence develops, we see genuine momentum behind a more unified, less burdensome model that serves markets and regulators better.
2026: the year data quality becomes the strategy
If 2024 was implementation and 2025 was stabilisation, 2026 will be optimisation—driven overwhelmingly by data quality. Supervisory attention is sharpening around:
* pairing and matching rates,
* timeliness and consistency of submissions,
* alignment on LEIs, UPIs, UTIs, and product taxonomies,
* field‑level accuracy that enables cross‑TR reconciliation.
To support this shift:
* Our analytics will focus more on systemic root‑cause detection, not just exception reporting.
* We will expand benchmarking so firms can assess performance against peers with real, actionable comparators.
* We will enhance tooling that helps firms manage identifiers and upstream data governance—the foundation of true, durable data quality.
What we’re doing next
Our 2026 roadmap focuses on reducing complexity and accelerating clarity:
1. Smarter reconciliation and diagnostics — enriched reason codes, workflow guidance, and improved cross‑regime transparency.
2. Enhanced client workspaces — dashboards consolidating rejections, timeliness, pairing/matching, and counterparty analytics in one place.
3. Friction‑free onboarding — removing the heavy papering.
4. Turning regulatory harmonisation into tooling — as ESMA’s work advances, we’ll translate policy concepts into practical artefacts (field mappers, schema bridges, interpretation notes).
5. Expanded community engagement — more face to face meetings, working groups, and RoundUp sessions focused on the real operational challenges firms face in EMIR EU, EMIR UK, SFTR, and FinfraG. And, of course, we are already preparing our flagship Annual Client Event taking place in October 2026.
What we recommend to participants
* Invest in upstream data governance. Golden sources for instrument and counterparty data will define your 2026 success far more than downstream fixes.
* Automated Data Mapping & Field Normalisation, Instead of manually harmonising fields across EMIR, EMIR UK, SFTR and FinfraG, firms can use:
- automated field‑mapping engines that translate internal attributes into regulatory schema values,
- taxonomy lookups for UPIs, LEIs, and CFIs,
- auto‑population rules for derived fields (e.g., action types, event types, collateral flags).
* Embrace benchmarking. Use market comparisons as developmental tools, not scorecards. The gap between “compliant” and “trusted” data is closing fast.
Community Insights & Knowledge Sharing
Many of these themes surfaced repeatedly in our conversations with the wider reporting community. Throughout the year, the REGIS‑TR Round‑Up podcast served as a platform for shared learning, bringing together Central Banks and National Competent Authorities, Customers, Industry Associations, Market Infrastructure and Vendors. Season 11 explored the evolving landscape across EMIR REFIT, MiFIR and global reporting regimes, along with related topics such as DORA, T+1, the Draghi Report and the Savings and Investment Union. With more than 16,000 downloads across 89 countries, the series reflects a broad appetite for practical insight and open dialogue across the industry.
The road ahead
Regulatory reporting is a team sport. In 2025, we proved that scale and stability can coexist with innovation and agile client support. In 2026, our aim is to drive the industry from compliant data to trusted data, from platform to partnership, from regulatory divergence to harmonised outcomes.
Thank you for your trust, your feedback, and your collaboration. Keep telling us where the friction is.
We’ll keep building the tools to remove it.