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On 4 May 2026, ESMA published its Final Report on the integrated collection of funds' data. This report, asked by the Commission under the revised AIFMD and UCITS Directive, sets out how supervisory and statistical reporting for AIFs, UCITS, MMFs and ECB statistics will eventually collapse into one framework.
What is actually being proposed
One modular reporting template would replace the current patchwork of AIFMD, UCITS, MMFR and ECB statistical templates. Core modules would apply to all funds. Modular approach would cover specific fund types (real estate, private equity), supervisory needs (leverage, liquidity) or thematic monitoring (portfolio holdings). Crisis-driven modules can be activated when needed.
Under ESMA’s proposed model, funds would submit data once to a single designated national authority, whether an NCA or NCB, as determined by each Member State. That authority would then transmit the data to a centralised EU hub maintained by ESMA ("report once, use many times"). All entitled authorities (ESMA, NCAs, NCBs, ECB, ESRB, EBA, EIOPA, NSAs) would draw what they need from the hub based on their mandate. National extensions are out, except in narrowly justified cases.
A common regulatory data dictionary would be put in place: one semantic layer across regimes, one syntactic model, ISO 20022 XML as the standard format, standard identifiers (LEI, ISIN, CFI) where available. ESMA explicitly aligns this with the Commission's horizontal data dictionary work and the ECB's IReF programme for banks.
Validation would be centralised at EU level, with a single set of rules and rejection criteria applied once. This would eliminate the current duplication whereby 27 NCAs independently perform additional checks on top of ESMA’s baseline. Granularity shifts toward security-by-security where it adds value. Revised AIFMD and UCITS RTS and ITS are expected to introduce more granular reporting requirements to enable more detailed and consistent breakdowns across multiple analytical dimensions. Aggregates stay where they cannot be reverse-engineered from raw data.
Reporting frequency will be calibrated to reflect the fund’s risk profile, scale and market relevance at module level, reflecting the supervisory relevance of the indicators derived from each module and the corresponding reporting burden for asset managers. This means that different supervisory modules may follow different reporting frequencies, enabling supervisory authorities to distinguish between a set of information requiring higher‑frequency and information that can be reported less frequently without undermining effective supervision.
What this means in practice
For ManCos and AIFMs, the medium-term picture is one set of definitions, one template, one submission. The short-term picture is the standard ESMA pattern: significant up-front IT and governance investment to migrate. ESMA admits this directly in the CBA annex and is honest that total cost goes up before it comes down.
National regimes that currently sit on top of AIFMD/UCITS reporting will either disappear or shrink to "duly justified" exceptions. For Luxembourg, this is a real simplification of the cross-cutting load ManCos carry today.
MMFR is parked for Phase 2. Level 1 thresholds and frequencies are too rigid to integrate immediately, but ESMA is signalling preparatory mapping work in parallel.
What to start doing now
- Analyse your current reporting obligations for AIFMD, UCITS, MMFR, ECB IFS, SHS, national templates to identify overlaps and gaps to help drive Phase 1 scope
- Run a high-level IT impact assessment against ISO 20022 XML and security‑by‑security (SbS) reporting if you are not already there. The consultation window at end-2026 will close fast
- Confirm your single national collection authority assumption (NCA or NCB)
- Watch the data dictionary workstream. The semantic layer is where the operational risk concentrates and where industry feedback matters most
How can EY help?
While the detailed RTS/ITS are still to come, ESMA’s final report already gives firms a clearer view of the future direction of fund reporting. EY can support clients with preliminary impact assessments, gap analyses and readiness planning across reporting processes, data architecture and governance, ahead of the next implementation phase.
Our team is here to guide you through the transition process and support you in achieving compliance with new requirements, including forthcoming detailed guidance.
For further clarifications or to discuss your specific needs, please reach out to our regulatory experts.
Summary
On 4 May 2026, ESMA published its Final Report on the integrated collection of funds' data. This report, asked by the Commission under the revised AIFMD and UCITS Directive, sets out how supervisory and statistical reporting for AIFs, UCITS, MMFs and ECB statistics will eventually collapse into one framework.
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