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Structural Regulation
02:01 AM 26th June 2026 GMT+00:00
Data Quality: Trade Reporting’s Next Big Challenge
Analysis by Oliver Williams
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The focus of trade reporting has shifted from timeliness to data quality, requiring more resilient operational models, says DTCC's Oliver Williams.
Over the last decade, the derivatives trade reporting landscape has evolved amid constant change from regulatory rewrites and the introduction of new data standards as well as growing technical requirements.
These reforms have expanded the volume and granularity of what must be reported, raising expectations not just for timeliness but for data quality, accuracy, consistency and completeness across jurisdictions as well as counterparties. For firms with cross‑border activities, aligning sources, controls and interpretations to produce usable, comparable data has become a significant operational challenge.
Recent regulatory initiatives have promoted the adoption of common data standards such as ISO 20022 XML message schema as well as global identifiers including Unique Product Identifier (UPI). On paper, these reforms are intended to simplify reporting and enable more consistent aggregation of data across markets. However, this has introduced further complexities. Firms are seeking a reporting process that is more resilient and adaptable.
As a result, the industry’s focus is shifting from whether firms have reported to how well they are reporting their data. Data quality, consistency and usability are no longer secondary considerations as they are increasingly central to regulatory scrutiny and firms’ ability to maintain operational resilience while meeting compliance expectations.
Making trade reporting data fit for purpose
Previously, the industry was focused on ensuring that trades were reported on time, but only relying on timeliness is no longer sufficient. There is a growing emphasis on the quality and consistency of trade reporting data, including the accuracy of trade reported details, whether fields are populated correctly, and alignment on counterparties submissions.
For firms operating globally, this introduces an additional layer of technical and resource challenges because it requires robust systems and reporting processes that support higher data quality requirements.
Buy‑side firms in APAC face a distinct set of challenges brought about by this evolution. Many rely on third parties to fulfil their reporting obligations, yet regulatory clarification around responsibility has made it clear that accountability lies with the buy-side firm.
As a result, this has led to a sharper focus on transparency. Buy-side firms need visibility into what is being reported on their behalf and the ability to assess whether those submissions meet regulatory standards. Without access to meaningful data and metrics, it becomes difficult to ensure that the reporting data is accurate.
This is not only a setback for buy-side firms because the same principle applies to firms that report directly. While direct reporting firms may have easier access to raw data, understanding whether that data aligns with regulatory expectations, or with peers in the market, remains a challenging task.
One-way firms are seeking to improve data quality is through the use of comparative analytics. By comparing reporting outcomes against peers, firms can identify gaps, prioritise remediation efforts and calibrate their controls against industry standards. This comparative analysis also adds valuable context, helping firms distinguish between firm‑specific issues and broader market challenges.
From a supervisory perspective, such peer-to-peer comparison has become increasingly relevant. As regulators enhance their analytical capabilities, firms can expect greater use of comparative analysis to assess the quality of trade reporting data across the industry.
From compliance to confidence
Data quality challenges are not purely technical as they are influenced by resource constraints. Skilled trade reporting subject‑matter experts continue to be in short supply. As a result, ongoing regulatory and operational changes have increased the demand placed on internal teams. In turn, many firms find themselves having to make strategic choices about how best to deploy limited expertise.
This has raised a crucial question on how firms can build sustainable trade reporting models without relying on tactical fixes. The answer lies in augmenting internal capabilities. By combining in‑house oversight with support from specialised partners or industry utilities, firms can access specialised skills, accelerate remediation efforts and establish more resilient, future-proof reporting frameworks.
As reporting and data management become more closely intertwined, clarity around governance and ownership is essential. Firms must be clear about who owns the data, who is accountable for its quality, and how issues are identified, escalated and resolved across the reporting lifecycle.
Specialised partners and industry utilities can support this by bringing structure, consistency and best‑practice insight, particularly in complex or multi‑jurisdictional environments. It is also critical to design controls and long‑term governance frameworks to achieve effective and sustainable reporting outcomes.
The future of trade reporting will be driven by continued regulatory evolution, advances in technology and rising expectations around data quality. Initiatives focused on common domain models and digital regulatory reporting point toward a more integrated and standardised environment, but their success will depend on strong data foundations, supported by effective use of technology and collaboration across the industry.
For firms, the opportunity lies in moving beyond compliance toward insight. High‑quality data can support better risk management, more efficient operations and the ability to report with confidence. Leveraging analytics and engaging with industry peers can further enhance performance measurement, transparency and shared learning as regulatory and operational demands increase.
As the industry enters the next phase of trade reporting, data quality is no longer considered just a reporting requirement – it has evolved into a critical cornerstone of effective and resilient reporting models.
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By Oliver Williams, Executive Director, Derivatives Business Management, APAC, DTCC.
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