2026 Regulatory Reporting: Trends, Challenges, and Expert Perspectives

Disclaimer: Statements by persons who are not S&P Global Market Intelligence employees represent their own views and opinions and are not necessarily the views of S&P Global Market Intelligence

 

#1 – ISDA’s Commitment to Fixing Global Reporting

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  Andrew Bayley, Senior Director, Data and Reporting, International Swaps and Derivatives Association  

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This has been a milestone year for ISDA, as we celebrated our 40^th anniversary with a series of special events and articles, reflecting on our journey from a small group of New York-based dealers to a global trade association with more than 1,000 members. As the year comes to an end, we are firmly focused on future opportunities to bring greater efficiencies to the derivatives market, one of which is data reporting.

It’s been a busy year for those who work in this area, with recent updates to reporting rules in Canada and Hong Kong coming hot on the heels of updates in five other jurisdictions last year. We have continued to evolve the ISDA Digital Regulatory Reporting (DRR) initiative, which converts an industry agreed interpretation of the rules into unambiguous machine-executable code. We’re seeing growing interest in using the ISDA DRR from firms that want to implement the rules more efficiently, cost-effectively and in line with the industry consensus, while also avoiding regulatory penalties for inaccurate reporting.

The reporting rule updates and the adoption of DRR are very encouraging, but we also recognize further work is needed to fix the flaws and inconsistencies in the global reporting framework. Even now, with updated rules in eight jurisdictions, there are omissions, duplications and inaccuracies in reported data, and regulators aren’t always able to extract the information they need from trade repositories to identify the build-up of derivatives exposures and risks.

That’s why we welcome recent steps taken by the European Securities and Markets Authority (ESMA) to seek industry feedback on the simplification of transaction reporting, addressing the major cost drivers and how the burden could be reduced while also ideally improving the quality of data submitted. Working with other trade associations to respond to ESMA’s call for evidence, we found a clear consensus on the key issues that drive up the cost of reporting in the EU. These include the obligation for both parties to report the same trade, duplicative reporting requirements under multiple regulations for the same derivatives instruments, and frequent changes in regulatory requirements.

We expect ESMA to publish a final report next year, and hope this will be the beginning of meaningful improvements to the EU reporting framework. As ISDA moves beyond its 40^th year, fixing the flaws in the global reporting framework to ensure the right data is efficiently and accurately reported will be a key priority.

#2 – 2026: The Year to Bridge the Transaction Reporting Chasm

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  Grant Haley, Director, Practice Lead Transaction Reporting and Regulatory Solutions, First Derivative

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The regulatory landscape for transaction reporting is on the brink of divergent change in 2026. This year kicked off with the FCA’s MiFID Industry forum in London, where proportionality and openness set the tone for a new era. The FCA’s focus on cost/benefit analysis, iterative standards, and practical guidance through TRUP, Tech Sprints, and the Transforming Data Collection program signals a more collaborative and proportionate approach for UK firms.

But as the months unfolded, ESMA’s Call for Evidence in June and the European Commission’s dramatic de-prioritization of 115 Level 2 acts in October left the industry in suspense. The EU’s decision to delay MiFID III and MiFIR implementation until at least 2028 has widened the regulatory gap, setting the stage for unprecedented divergence. This split will ripple through market infrastructure, reference data, and reporting chains.  Firms operating cross-border will be forced to manage dual builds, reconcile conflicting requirements, and navigate heightened risk.

Divergence is now hardwired, not just a matter of a few fields or templates. The FCA’s ‘Ala Carte’ approach is pragmatic and consultative, while ESMA’s ‘All You Can Eat Buffet’ keeps every option on the table. Firms must be ready to adapt to two distinct regulatory philosophies, each with its own challenges and opportunities.

For 2026, the mandate is clear: treat this as your control year. Build a single semantic core, establish robust data lineage, and implement explainable controls. Remediation, documentation, and governance are non-negotiable, as underscored by the FCA’s Market Watches (81, 82, and 84). Vendor strategy is critical, open-source standards like ISO 20022 and CDM/DRR are disrupting proprietary models, and firms must ensure their architecture is modular, interoperable, and future-proof.

Baseline your regulatory reporting data on global standards, assign clear data ownership, and document lineage, rule mapping, and controls in strategic solutions. High-quality data is the bedrock for leveraging AI and intelligent automation, and a well-governed data model will be essential for defensible, resilient reporting.

Even if the regulatory change pipeline for 2026 looks lighter, complacency is not an option. Now is the time to take stock, remediate legacy issues, strengthen governance, and future-proof your reporting architecture. Proactive investment in data quality, documentation, and strategic vendor alignment will ensure you’re ready for the next wave of regulatory change and turn divergence into your competitive advantage.

#3 – SEC Rule 10c-1a: Preparing for a New Era of Transparency in Securities Lending 

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  Fran Garritt,  CEO and President, International Securities Lending Association Americas (ISLA Americas)

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The Securities and Exchange Commission (SEC) has adopted Rule 10c-1a under the Securities Exchange Act of 1934 to enhance transparency in the securities lending market. While public debate continues over the final provisions and implementation timeline, the compliance dates for Rule 10c-1a have now been extended, with required reporting to an RNSA beginning on September 28, 2028, and public dissemination beginning on March 29, 2029. Even with the revised timeline, it remains prudent for industry participants to begin anticipating requirements and developing strategies to ensure compliance.

ISLA Americas views implementation of this new regulation as an opportunity for the industry to refine governance frameworks and elevate data standards. As the final regulatory requirements continue to take shape through active dialogue among regulators, market participants, and standard setters, ISLA Americas will continue its involvement ensuring that the guiding principles of clarity and consistency continue to be applied in this next phase of regulatory development. At the same time, our focus remains steady: supporting accurate disclosure without imposing undue burdens on the trading and financing activity that supports market efficiency.

Although no binding commitments have yet been made regarding the Rule’s final provisions or ultimate form, the updated timeline provides additional clarity for planning. Close engagement with industry bodies remains essential to ensure that the final requirements reflect operational realities and avoid unintended restrictions on market activity.

Predictability in the Rule’s design is critical for the industry, and it is understandable that beneficial owners and agent lenders may hesitate to incur costs before the requirements are finalized. Nevertheless, proactive investment that strengthens data lineage, quality controls, and reporting capabilities will deliver long term value once the Rule’s implementation path, including the September 28, 2028, reporting start date and the March 29, 2029, public dissemination date, is fully in place.

Prudent preparation should now guide industry planning. Measured investment in scalable and resilient infrastructure can ease the transition and position firms for efficient, confident reporting. At the same time, compliance teams should continue strengthening documentation, governance structures, and internal controls to ensure readiness within approved risk frameworks.

As the mechanics and timing of Rule 10c-1a continue to evolve, market participants can be assured that its core reporting elements will remain central to the final Rule. ISLA Americas will continue to engage with regulators by offering guidance, sharing best practices, and advocating for a balanced, stable reporting approach that enhances market integrity while working in harmony with existing operational frameworks. Ultimately, ISLA Americas’ overarching objective remains unchanged: to promote transparent markets that protect investors, enable efficient capital formation, and encourage technological innovation in line with evolving regulatory requirements.

# 4 – Navigating the Next Wave of OTC Derivatives Regulations: Hong Kong, Asia and Beyond

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  Andrew Fei, Partner, King & Wood Mallesons 

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Although Hong Kong’s ‘big bang’ implementation of OTC derivatives reporting rewrite went live in September 2025, derivatives regulatory reforms are far from over. The next wave of reforms — spanning licensing, capital, margin and digitization — will reshape how market participants operate in an increasingly complex world.

Hong Kong Type 11 Licensing

Hong Kong’s long-awaited ‘Type 11’ licensing regime for dealing in or advising on OTC derivatives is moving closer to implementation, following the Securities and Futures Commission’s (SFC) advancement of amendments to the Securities and Futures (Financial Resources) Rules (FRR).

Notably, banks regulated by the Hong Kong Monetary Authority are exempt from the Type 11 licensing requirement. This places the licensing compliance burden squarely on securities houses and other non-bank entities. For these firms, the past practice of booking derivatives in non-licensed affiliates may no longer be viable, and they will need to ensure that a complaint legal entity—subject to Type 11 licensing and SFC oversight—is the counterparty to Hong Kong client trades. This will require a holistic review/revamp of booking models, documentation, risk management and operational processes.

New FRR

The SFC’s proposed amendments to the FRR represent the most significant overhaul of Hong Kong’s capital rules for SFC-regulated licensed corporations (LCs) in over a decade. The 430-page rulebook, years in the making, will further align these capital rules with the Basel III bank capital requirements for derivatives and similar transactions. Significantly, the revised FRR will require LCs to obtain legal opinions confirming the enforceability of netting arrangements in all relevant jurisdictions.

Tokenized Collateral

Global regulators are actively considering whether and how tokenized assets can be used as eligible collateral for regulatory margin. This is an area to watch, as the digital asset revolution could have far-reaching implications for collateral management.

Basel III

On the banking side, the global rollout of Basel III final reforms continues to create challenges and opportunities. While many major jurisdictions have implemented the new standards, US implementation remains uncertain, with potential delays and divergences. This fragmentation risks creating an uneven playing field, particularly in Asia, where US, EU and local banks compete head-to-head.

Various jurisdictions, including Hong Kong, have also begun implementing the Basel Committee’s prudential standards for banks’ crypto asset exposures which, among other things, impose capital requirements on digital asset derivatives.

China UMR

A major development in 2025 is the publication of Mainland China’s uncleared margin rules, which are broadly consistent with the global standards. Chinese financial institutions and their counterparties face significant implementation work to achieve timely compliance. This includes negotiating a plethora of complex margin documents, upgrading collateral systems, ensuring robust operations and obtaining tailored collateral opinions.

Looking Ahead

The regulatory landscape for OTC derivatives is becoming more complex. Financial institutions and their corporate clients must stay abreast of fast-moving developments to remain compliant and seize opportunities for efficiency and competitiveness.

In this environment, leveraging robust regulatory compliance and risk management solutions is essential. AI-enabled and future-proof compliance solutions offered by firms such as S&P Global Market Intelligence can help firms navigate regulatory complexity with confidence. Those that invest in tried-and-tested and scalable solutions are best-positioned to thrive as the next chapter of derivatives regulation unfolds.

# 5 – The Evolution of Trade Reporting

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  Guy Pilson Whitley, Chief Delivery Officer & Head of GTM, G MASS and ace

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Having cut my T&TR practitioner teeth during the dawn of EMIR in 2013/14, that period felt like a new era for regulatory expectations. More than a decade on, we’ve moved well beyond the teething stage, and the market opportunities and challenges that once felt out of reach are now very much in scope. I believe we’re entering the most exciting period for trade and transaction reporting in our history:

1. 1. Regulation now evolves incrementally, forcing constant refinement. Data completeness, accuracy and timeliness have always been the name of the game, but with expanding field counts, data integrity is now the battleground. Global authorities are consistent: firms must remediate all errors and omissions, making self-assurance a core operational discipline;

 

1. 1. Convergence around a common language – CDEs, UTI/UPI identifiers and ISO 20022 XML – is finally giving the industry the foundations it has long needed. Re-writes and new mandates alike are now baselining against these standards, sweeping away the translation “cobwebs” that created years of friction between counterparties. We can now genuinely focus on speaking the same language;

 

1. 1. Data-office concepts such as governance, lineage and traceability are now part of everyday business language. AI has accelerated this shift. Use cases like horizon scanning, rule interpretation, ISO mapping and exception triage show real promise, but they also raise expectations. Supervisors want AI to be explainable, auditable and bias-free; firms need rigorous model governance and clear lineage of how decisions are produced; and

 

1. The vendor landscape has exploded, with full-service platforms and niche RegTechs often overlapping in functionality. As costs rise, firms are consolidating vendors, simplifying architectures and even bringing some reporting functions back in-house. The likely destination is a hybrid model: internal ownership of core data and controls, selectively augmented by external technology and expertise. Ultimately, firms want tighter oversight of their reporting destiny.

 

#6 – The Regulatory Tide: Stablecoins, DLT, and the Future of Fintech

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  James Mcloughlin, Managing Director, Osttra

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The global financial landscape is undergoing a profound transformation, powered by Distributed Ledger Technology (DLT) and stablecoins. Stablecoins, digital assets pegged to fiat currencies, offer the stability of traditional money combined with the efficiency of DLT, positioning them as a critical medium of exchange for the digital age.

Understanding the New Digital Pillars

Digital assets are any assets existing solely in digital form, encompassing cryptocurrencies, tokenized assets, and stablecoins. DLT is the decentralized database technology that underpins most of these assets. By eliminating the need for a central authority, DLT promises enhanced transparency, security, and efficiency across financial operations, from cross-border payments to capital market settlements.

Transatlantic & International Regulatory Efforts

Global regulators are moving swiftly to address the promise and risks of these innovations. A key development is the formation of the Transatlantic Taskforce for Markets of the Future between the US and the UK. Operating under the existing Financial Regulatory Working Group, this bilateral effort is focused on aligning approaches to stablecoin regulation, aiming to establish common ground on stablecoin issuance standards, custody, and cross-border compliance. This coordinated approach is vital for reducing friction for firms operating in both jurisdictions and preventing regulatory arbitrage.

Concurrently, international taskforces like the Financial Stability Board (FSB) and IOSCO are developing global standards for “global stablecoin arrangements.” Their primary goal is to ensure that stablecoins, particularly those that may become systemically important, are consistently regulated across borders to safeguard financial stability and consumer protection.

Implications for Fintechs

This wave of regulatory clarity presents both a challenge and an immense opportunity for Fintechs:

• • Opportunity for Innovation: Clear, aligned regulation reduces uncertainty, offering a stable environment for Fintechs to build innovative DLT-based products. This includes faster, cheaper cross-border payment solutions utilizing stablecoins. Furthermore, the Federal Reserve is exploring “skinny” payment accounts for Fintechs, allowing them to settle transactions directly with the Fed. This would integrate seamlessly with DLT systems to provide near-instant, inexpensive transactions, directly challenging existing high-fee payment rails.

 

• • Challenge of Compliance: New rules demand substantial compliance investment. Systemic stablecoin issuers will face stringent reserve quality requirements (e.g., holding high-quality, liquid assets) and regulatory oversight, often mirroring those of traditional financial institutions. Fintechs must adapt rapidly, viewing robust regulatory engagement not as a barrier, but as a strategic competitive advantage.

 

In conclusion, the collaborative regulatory efforts by the US/UK and international bodies are constructing the necessary framework for a more secure, efficient digital financial ecosystem. Fintechs that proactively adopt these emerging standards and harness the power of DLT are poised to dominate the next chapter of global finance.

# 7 – South Africa’s Path to a Robust Trade Repository and Transaction Reporting

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  Farzana Khan, Head of Collateral Services and Trade Repository, Strate

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In November 2024, Strate, South Africa’s principal CSD, was awarded a licence to operate the country’s first Trade Repository (TR). The focus in 2025 has been on agreeing the reporting standards and implementation approach. The South African regulations for transaction reporting were published in 2018 and have not kept pace with global developments since then.

We chose a collaborative approach, forming a TR Working Group comprised of market participants and regulators, to co-create a fit-for-purpose solution that was modelled on EMIR Refit but accommodated South African nuances. The TR Working Group approved the TR’s Business Requirements and Technical Interface Specifications in September 2025. This document is available on our website. We deeply appreciate the comprehensive input and experiences shared by ISDA and other seasoned regulatory reporting specialists that participated in this process.

As a next step, the regulations will be updated prior to implementing transaction reporting. We expect this in 2027, with the date determined by the Authorities.

Some challenges we foresee for implementation concern the standard identifiers of transactions: Legal Entity Identifiers (LEI), Unique Product Identifiers (UPI) and Unique Transaction Identifiers (UTI).

For LEI, no explicit regulatory requirement currently exists for all market participants to adopt LEI, though it is strongly encouraged by the Authorities. This is being rolled out through various Conduct Standards that will require LEIs to be reported, with OTC derivative transaction reporting being such an example. The challenge is that the Conduct Standard is applicable to OTC Derivative Providers (ODP) but ODPs will require their clients to adopt LEI to enable them to comply with the Conduct Standard.

For UPI, there is broad consensus on the benefits of adoption, but concerns remain about the cost of membership to ANNA DSB, especially for smaller ODPs. We are in ongoing discussions with ODPs and ANNA DSB on this and will seek resolution in 2026.

For UTI, the focus is on finding the most pragmatic way for ODPs to share UTIs for ODP-ODP transaction reporting. This work will also continue in 2026.

Apart from OTC derivative transaction reporting, draft Conduct Standards on the reporting of short sales and securities finance transactions are also expected to be reported to the TR, which will make 2026 a very busy year!

#8 – Data Quality vs. Simplification: Lessons from EMIR REFIT and the Road Ahead

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  María Santos, Head, REGIS-TR, SIX

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When the European Market Infrastructure Regulation (EMIR) REFIT went live in the EU in April 2024 and in the UK five months later, the stated ambition was clear: improve data quality and streamline compliance. For trade repositories like REGIS-TR, this was a transformational moment – introducing ISO 20022 XML, expanding reportable fields from 129 to 203, and embedding global identifiers such as UPIs and CDEs. These changes were designed to enhance transparency and systemic risk monitoring. But has simplification truly been achieved?

The recent ESMA Call for Evidence on reporting simplification underscores the tension at play. While ESMA is exploring ways to reduce complexity, the additional reconciliation fields mandated under EMIR REFIT are unlikely to be put on hold. Nor is there any indication of regulatory leniency on compliance. For market participants, this means that the significant investment already made—overhauling systems, mapping data to new schemas, and implementing robust control frameworks—remains essential. There is no “pause button” on data quality.

This reality raises a critical question: does simplification equate to fewer obligations, or does it mean harmonization and clarity? For firms now facing proposals such as reporting delineation by instrument type or even single-sided reporting, the answer is far from straightforward. Re-engineering processes to accommodate these changes could introduce fresh complexity and cost, undermining the very goal of simplification. It should not come at the expense of consistency and accuracy – especially when regulators have made clear that high-quality data is non-negotiable.

Welcoming efforts toward simplification and consistency is important, as these initiatives can only lead to a more useful and efficient supervisory use of the information provided by industry participants. However, it must be recognized that a change of such magnitude requires broad consensus and a phased implementation. This is particularly critical given the significant investments made just a year ago for the implementation of REFIT and the experience gained in adapting to such a substantial transformation.

Post-Brexit divergence adds another layer of challenge. While EU and UK regimes remain broadly aligned, differences in implementation timelines and technical standards are likely to emerge. For dual-reporting entities, this means maintaining compliance across two similar – but not identical – frameworks. In practice, this often translates into additional cost, effort, and operational risk.

Ultimately, any change will need to be carefully managed and it’s important to understand the journey and inherent challenges posed. In this regard, trade repositories are uniquely positioned to help simplify the existing reporting burden placed on firms and supporting any transition to new reporting standards over the longer term.

The bottom line? Simplification is not about shortcuts. It’s about smarter processes, better technology, and collaboration across the industry. As ESMA’s consultation makes clear, the debate is ongoing, but one thing is certain: data quality remains the cornerstone of effective regulation.

#9 – European SFT Clearing: Collaborative innovation that drives democratization

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Edward Sharpe, Head of Post Trade Services, Pirum

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In 2025, European Securities Finance Transactions (SFTs) took a major step forward as the centrally cleared model for bilateral European SFTs became a reality. April marked a watershed moment when Natixis Corporate & Investment Banking and J.P. Morgan became the first firms to use Cboe Clear Europe’s innovative clearing service. The momentum continued in November as Cboe Clear Europe and BNY extended SFT clearing to UCITS funds, significantly broadening market access.

The clearing model’s evolution also aligns with 2025’s defining trend: comprehensive automation of post-trade processes. Real-time trade instruction and lifecycle event processing are enabling firms to achieve T+1 settlement – and position themselves for T+0 – well ahead of Europe’s October 2027 accelerated settlement deadline. More importantly, this infrastructure provides the standardized, enterprise-wide real-time data that has become essential for competitive advantage in an increasingly digitalized marketplace.

Looking ahead to 2026, the globalization of clearing will continue to accelerate. However, technology alone cannot drive this transformation. The securities finance industry’s evolution toward real-time, AI-ready infrastructure depends fundamentally on collaboration – market participants working together to solve real-world problems rather than pursuing isolated solutions.

The democratization of centrally cleared bilateral SFTs exemplifies this collaborative approach. When CCPs, custodians, technology providers, and market participants align around shared objectives, the entire ecosystem benefits. This model of collective innovation, rather than competitive fragmentation, will prove critical as the industry navigates the complex challenges ahead: compressed settlement cycles, increased regulatory scrutiny, and the need for interoperable systems across jurisdictions.

#10 – Unlocking Efficiency: How Data Management Will Transform Transaction Reporting by 2026

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 Struan Lloyd, Head of Cappitech at S&P Global Market Intelligence, Cappitech 

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Disclaimer: Statements by persons who are not S&P Global Market Intelligence employees represent their own views and opinions and are not necessarily the views of S&P Global Market Intelligence