On 31 July 2026 the first reporting submission under the EMIR 3 active account requirement fell due. It covered a reference period reaching back to 25 June 2025, when the obligation started to apply. For the counterparties concerned this was not a one-off exercise: reporting is now semi-annual, and it feeds a monitoring framework ESMA has already begun to use.
What happened on 31 July
The active account requirement obliges the counterparties in scope to hold an account with a clearing house established in the Union for products considered systemically important: OTC interest rate derivatives denominated in euro and Polish zloty, and short-term interest rate derivatives in euro.
The practical conditions were set by Commission Delegated Regulation (EU) 2026/305, published in the Official Journal on 6 February 2026 and in force since 26 February 2026. That text specifies three things: the operational conditions of the account, the representativeness obligation, and the content of the regulatory submission.
ESMA has issued CSV reporting templates aligned with Annexes II and III of the delegated regulation, together with the technical instructions. Submission does not go through a European portal: each national competent authority communicates its own transmission channel.
A calendar that becomes routine
| Deadline | Reference period | Scope |
|---|---|---|
| 31 July 2026 | 25 June 2025 to 30 June 2026 | First submission, including backlog data |
| 31 January 2027 | Rolling twelve months | Semi-annual submission |
| 31 July 2027 | Rolling twelve months | Semi-annual submission |
The point sits in the third column. The first submission covered thirteen months and meant reconstructing data that was sometimes old. The following ones cover rolling twelve-month periods: the collection effort does not disappear, it shifts towards continuous production.
ESMA has started measuring the effect
On 6 July 2026 ESMA published two documents that show how closely it is watching: an interim report on the effectiveness of the active account requirement, and the first annual report of the joint monitoring mechanism established by EMIR 3.
For a counterparty this changes how the exercise should be read. The submission does not only feed an individual compliance check: it feeds an aggregate assessment of the effect of the regime on where clearing takes place. The quality of the data submitted therefore matters beyond each firm’s own file.
The consolidated tape moves in parallel
The MiFIR review is progressing on another front. ESMA selected EuroCTP as the applicant most suitable to operate the consolidated tape for shares and ETFs, then, on 6 July 2026, Etrading Software (Netherlands) B.V. for OTC derivatives. The selection runs for five years and opens an authorisation and supervision phase with ESMA.
The two workstreams converge more than they appear to. The active account requirement moves clearing towards the Union; the consolidated tape makes European market data readable. In both cases the real demand on firms is the same: produce traceable, timestamped and reconcilable data.
What this changes for you
- Treat the submission as a process, not a project. The first deadline mobilised teams in exception mode. The semi-annual cadence now calls for a named owner, a collection calendar and a consistency check before transmission.
- Document the audit trail now. The reports ESMA published in July show that the data submitted will be used in aggregate. Data that cannot be reconciled with your clearing systems will be hard to defend.
- Bring clearing and market data teams together. Active account and consolidated tape sit in separate texts but rely on the same instrument and counterparty reference data. Handling them separately means paying twice for the same data quality work.
These subjects are run as projects, against regulatory milestones that are not negotiable. Helios Advisory supports firms on the governance of this work and designs training paths for the teams involved: see Banking and Financial Projects.
Regulatory watch
- 24 July 2026 — EBA. The European Banking Authority released, ahead of schedule, the draft technical package for version 4.4 of its reporting and disclosure framework: IFRS 18-aligned FINREP templates, amendments to the ITS on Pillar 3 ESG disclosures, and integration of FRTB disclosure templates. Feedback is due by 24 August 2026, with the final package expected in September 2026. EBA press release
- 27 July 2026 — ESMA. Following the selection reported above, the authority formally authorised EuroCTP B.V. as the Consolidated Tape Provider for shares and ETFs, with a transition period until 30 September 2026, followed by five years of operation under ESMA’s direct supervision within the MiFIR framework. ESMA press release
Sources
- ESMA — Reporting templates and instructions for the Active Account Requirement
- ESMA — Interim report on the effectiveness of the active account requirement, 6 July 2026
- ESMA — Final report on the active account requirement under EMIR 3
- ESMA — Selection of the consolidated tape provider for OTC derivatives
- ESMA — Selection of EuroCTP for shares and ETFs
- EBA — Draft technical package 4.4, 24 July 2026
- ESMA — Authorisation of EuroCTP as CTP for shares and ETFs, 27 July 2026
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