With the focus increasingly on data quality rather than ticking boxes, DTCC's Michele Hillery stresses the need for keeping things consistent.

As reporting frameworks diverge between the UK and EU, firms are facing a new phase of regulatory complexity, in addition to supervisory expectations for data submitted to be accurate, consistent, and defensible across jurisdictions.

Although MiFID II/R is a piece of European legislation, many APAC banks find themselves affected by these rules, particularly in cases where transactions are executed, booked, or reported through entities within either the UK or EU.

Despite leaving the EU, the UK has kept MiFID II/R on its statute books, though it is currently seeking to streamline reporting and simplify requirements. Meanwhile the EU’s financial markets regulator, ESMA, has signalled a broader, more holistic review across MiFID, EMIR, and SFTR, including the potential for consolidated reporting frameworks.

“Following successive refits and rewrites, we’ve seen a shift. In addition to data completeness checks, i.e. ‘is the data there?’, there is a greater focus on data accuracy,” says Michele Hillery, Head of Repository & Derivatives Services at DTCC. “Data accuracy becomes even more important when firms are operating across multiple jurisdictions and supervisory expectations are not identical.”

Data accuracy

Strengthening data quality means going beyond simply populating mandatory fields. It is about demonstrating that the data submitted is accurate and able to be validated against other sources when necessary.

“Industry experience shows us that some firms are still focused on format-level checks rather than really checking whether reported data accurately reflects the underlying transaction,” says Hillery. “This is not a one-off exercise. Too often, firms fail to appreciate the importance of continuously monitoring data quality.”

“Effective reporting depends on robust control frameworks, clear ownership of reported data, and the ability to identify and remediate issues before they become supervisory concerns,” she says. “Firms often struggle when they rely purely on basic completion checks rather than identifying deeper inconsistencies that only become visible through benchmarking and cross-data comparison.”

This is where DTCC’s analytics capabilities can support firms, delivered through its Trade Reporting Analytics (TRA) offering. By enabling ongoing monitoring of data quality, cross-jurisdiction benchmarking and exception identification, the platform helps firms move beyond point-in-time validation towards continuous oversight of reporting accuracy. This in turn allows issues to be surfaced earlier in the reporting lifecycle and resolved before they escalate into regulatory concerns.

One pain point for firms, according to Hillery, is back reporting, which is the requirement to submit or correct information on historical transactions where trades were either not originally reported or were reported inaccurately.

To resolve this, DTCC has developed a corrections engine as part of its UK MiFID ARM service that leverages large language models, allowing users to easily type in queries to fix legacy data sets. DTCC is also in the process of integrating its TRA solution into its ARM framework to help firms meet the demand for increased data quality in their MiFID reporting.

“There is a clear regulatory-driven imperative for firms to focus on data quality,” says Hillery. “DTCC’s goal has been to provide the tooling and practical support to help clients address those challenges ensuring the most accurate data possible.”

Cross-border consistency

MiFID II/R introduced more structured reporting frameworks and common data elements. However, consistency in interpretation and implementation remains a key challenge for firms operating across multiple jurisdictions.

“Achieving consistent reporting outcomes across jurisdictions requires treating data as a shared, enterprise-wide asset rather than jurisdiction-specific obligations,” says Hillery.

“MiFID may have brought greater structure into the reporting process, but differences in interpretation and implementation across supervisory regimes can still lead to divergent outcomes unless the process is carefully managed.”

To mitigate this risk, Hillery says, firms should collaborate globally to come up with “common data definitions, consistent interpretation of critical data elements and controls that can identify divergences early.”

She adds that cross-jurisdictional testing is vital in this. “By comparing how the same transaction is reported under MiFID and other regulatory regimes, firms can identify interpretation gaps early and reduce the risk of inconsistent reporting outcomes,” says Hillery.

This requires the right operating model that spans multiple obligations rather than treating reporting regimes in isolation. Strong governance is equally important. Firms need central oversight of how critical data elements are sourced, interpreted, and maintained across reporting frameworks, instead of allowing decisions to evolve independently within each jurisdiction.

“As regulatory frameworks continue to evolve, the need to look beyond reporting as a tick-box compliance exercise is only going to get stronger,” says Hillery. “ARM solutions are an important part of this by strengthening controls, improving confidence in the data being reported, and helping firms remediate issues early in the reporting lifecycle.”