If you read 10 different articles about ESMA’s new unified reporting framework for investment funds, you may well see 10 different references to the dates, ranging anywhere from April 2027 through to 2029.
In this article, Seamus O’Cuill explores the key ESMA unified reporting dates and the reasons for the confusion.
Core Requirements
The basic requirement laid out in the legislation is that, from 16 April 2027, Member States will need to require AIFs/AIFMs to report additional information and also require UCITS to report for the first time. The data in scope for this reporting dates from 16 April 2026.
How National Competent Authorities (NCAs) require this reporting – including content, frequency, timing and format – in the absence of the final Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) remains to be seen.
However, managers need to be ready to report as required.
Understanding the ESMA Unified Reporting Dates
When do NCAs need to start collecting data?
Under UCITS VI and AIFMD II, firms are mandated to start reporting to NCAs from 16 April 2027.
The NCAs have, to date, given no guidance as to the format, frequency and content of this reporting.
The confusion is further exacerbated by the fact that ESMA is only mandated to propose new draft RTS and ITS by the same date – 16 April 2027. It is therefore not possible, as things stand, for the NCAs to immediately adopt ESMA standards. Each individual NCA will therefore need to advise how they wish to receive the reporting.
This has led to some speculation that the reporting might be put on hold, or that AIFMD Annex IV could continue using the same template, with UCITS joining on an interim basis.
However, that is speculation, and it is difficult to see how, legally, the NCAs cannot start collecting the reporting as it is required under EU law.
When might the ESMA unified reporting templates go live?
The draft RTS/ITS are due to be delivered by 16 April 2027. A “best case” guesstimate would be that these go through the EU approval process and are live in August 2027. It could be longer.
This could mean that the NCAs will be able to start asking for reporting in the new ESMA unified reporting format as early as August 2027. However, there could be an implementation timeline built in to allow firms to move to the new reporting requirements.
This will not eliminate the need for NCAs to collect data from 16 April 2027, so they could well insist on getting data in the new format in the absence of any other known common format.
When might reporting switch to the new ESMA Reporting Hub?
ESMA has indicated that the new EU Centralised Reporting Hub will not be available until 2029 at the earliest, so reporting will take place via the NCAs up to this point.
Hopefully, the next few months will bring greater clarity, but the message must be to get ready now.
The introduction of ESMA unified reporting for AIFs and UCITS represents a significant change to the way investment fund data will be collected and reported across the EU. While the precise reporting format, frequency and implementation timetable are still developing, firms should not wait for every detail to be finalised before preparing.
Understand the Full Impact of UCITS Reporting Changes
We have set out the full detail in our briefing paper, covering the key changes to the reporting framework, the impact across AIFs and UCITS, implementation timelines and regulatory milestones, as well as practical considerations for firms at different stages and how our Galaxy platform supports Annex IV and UCITS reporting.
Designed for UCITS and AIF managers assessing their reporting readiness.
