On 27 March 2026, five days before the planned start, the European Securities and Markets Authority (ESMA) withdrew the go-live of the revised weekly position report for commodity derivatives. In its notice of the same day the authority pointed to problems in the final testing phase that called for further corrections to system stability and data quality. On 14 August it confirmed a new date, 3 September 2026, and published the updated reporting instructions, the technical specifications and the validation rules alongside it. The date is confirmed, and it has been confirmed once before.
Read as a change of format, the switch looks smaller than it is. Little changes in what has to be reported: the same contracts, the same venues, the same calendar week. What grows is the number of statements that have to agree with one another. One submission becomes two reports, and each of the three measures splits per category into two component values whose sum must match the total on display. Five categories of position holder, each once long and once short, each with three measures: multiply that out and you arrive at thirty reconciliation equations per report, and sixty per contract and week. Neither ESMA nor the Federal Financial Supervisory Authority (BaFin) has published a grace period for the switch. The first submission is therefore also the first real test.
What: revised reporting package for the weekly aggregated position report under Art. 58 (1) a MiFID II, go-live 3 September 2026
Who reports: operators of trading venues on which commodity derivatives or emission allowance derivatives are traded
To whom: to ESMA through the upload channel; the authority validates, publishes and makes the checked data available to the national supervisors
German legal reference: section 57 WpHG, official heading Position reporting; enabling provision
Legal basis of the reform: Directive (EU) 2024/790 of 28 February 2024, given shape in ESMA final report ESMA74-2134169708-7577 of 16 December 2024
Two reporting chains, and only one of them switches
What tends to get confused here is the addressee. Art. 58 of the Markets in Financial Instruments Directive (MiFID II) sets out two separate reporting routes, and only one of them switches on 3 September. The one affected is the weekly aggregated report under Art. 58 (1) a. The venue operator files it with ESMA, the authority checks it, publishes it centrally and makes it available to the national supervisors; the venue publishes the report itself as well.
The daily report under Art. 58 (1) b stays as it is. There the members and participants of a venue report the positions of their clients and of those clients’ clients down to the end client; the operator collects those reports and files them with BaFin rather than ESMA. Both chains sit in section 57 WpHG under the official heading Position reporting, and for internal planning the first operational question of all hangs on telling them apart: which interface gets touched. A reference to section 54 WpHG, which is often quoted in this context, misses the point, because that provision governs position limits and therefore a different subject.
One submission becomes two
Four changes to the reporting package matter operationally, and they interlock. ESMA set them out in its final report of 16 December 2024 and spelled them out in the Interface Specifications Document, version 2.0. The first is the split of the weekly report. The report type field now distinguishes a submission that combines options and futures from one that carries futures alone. What used to be a single delivery becomes two from 3 September, each with its own timestamp, its own status and its own validation.
The second change concerns the position holders. In place of the earlier breakdown, the reporting instructions set out five categories, each for long and for short positions: investment firms and credit institutions, investment funds, other financial institutions including insurers, reinsurers and occupational pension schemes, commercial undertakings, and, for emission allowance derivatives only, operators with obligations under the emissions trading system. The fifth category therefore exists in some contracts and not in others, and populating it generically produces it where it does not belong.
The third change is the split by purpose, and it is the one that multiplies the workload. Each of the three measures, meaning the number of positions, the change on the previous report and the share of open interest, is reported per category separately for positions that directly reduce risks relating to the commercial activity and for all others. The two parts must sum to the total on display, and under the validation rules published on 14 August a dedicated rule checks exactly that. One reported figure becomes three, two of which have to produce the third.
The fourth change redraws the edges. Emission allowances in the spot market drop out of position reporting, emission allowance derivatives stay in expressly and form the fifth holder category. For energy derivatives the units of measure have been harmonised; the Interface Specifications Document admits lots, megawatt hours, million British thermal units and therms. A unit that used to pass because nobody checked it now runs against a list.
The version number refers to the package, not to the message
ESMA speaks of an XML schema in version 2.0, and that figure is the likeliest source of error in the first week. It denotes the document package, meaning the Interface Specifications Document for weekly position reporting. Under the technical specifications the underlying ISO 20022 message stays as it is at auth.051.001.01 in version 01. Raise a message-version check to 2.0 in good faith, because the authority talks about version 2.0, and the submission departs from the schema and is rejected at file level before a single content rule has run.
Where a submission fails before anyone reads it
Validation operates at two levels, and the first admits no tolerance. At file level submissions fail on a departure from the schema, on an unpacking error or on a wrong version of the message identifier. Only then do the content rules apply: they reject a reporting date in the future, require a report status consistent with the database, insist on numeric values in the long and short fields, check the sum control from the purpose split, and match the venue identifier against the stored table.
The way back from a rejected report runs through one of three statuses: new report, amendment or cancellation. Which of them fits depends on whether the rejected submission reached the authority’s records, and that question is hard to settle on reporting day. It belongs in writing beforehand.
No grace period has been communicated so far. Neither the ESMA documents nor the BaFin guidance names a transitional arrangement for the switch. That says nothing about how the supervisor will react in an individual case; it records that no arrangement has been published. Anyone budgeting for leniency on the first reporting day is budgeting against a document that does not exist.
The gap the publication itself creates
The thresholds for the publication obligation are unchanged from the previous package. A report is published where at least twenty open position holders are active in a contract at a venue and the absolute gross size of the long or short positions exceeds four times the deliverable supply. The second condition falls away for contracts without physical delivery and for emission allowance derivatives.
One detail alongside carries more weight than it appears to: where fewer than five position holders are active in a category, their number is not published. The finer the breakdown, the fewer holders fall on average into any one category, and the more often that number drops out of the publication. A finer split raises the resolution of the report and lowers the resolution of what is published. Market analysis built on the published data will meet systematic gaps from September onwards, at precisely the points where concentration is highest.
The reporting duty grows, the control powers stay
Position reporting is an instrument of transparency. Setting and monitoring limits runs through a separate legal act and through BaFin general rulings, the most recent of which is dated 10 February 2026. Planning both in one workstream joins two regimes that share nothing but their data.
Art. 57 (8) MiFID II as revised by Directive (EU) 2024/790 leaves the four control powers of trading venues unchanged in substance. They remain monitoring, requesting information, ordering a reduction or termination of positions, and the temporary obligation to provide liquidity. Only the scope is new: the controls now apply to venues on which emission allowance derivatives are traded. The same extension that creates the fifth category on the reporting side therefore reaches a new group of venues on the control side.
London moves the other way
For firms authorised in both the European Union and the United Kingdom the comparison is worth drawing, because the two regimes have measurably diverged since this summer. Under the policy paper of the Financial Conduct Authority of February 2025 responsibility for position limits sits with the trading venues; the final rules have applied since 6 July 2026. Limits there now bite only for a narrower set of especially significant contracts, and for everything else the venue decides.
The direction runs opposite, and it does so on both axes at once. The European Union deepens the reporting duty and leaves the control powers untouched; the United Kingdom narrows the limit duty and moves it to the venues. Firms serving both regimes will run two logics side by side from September: one in which the supervisor wants to see ever more finely, and one in which it wants to intervene ever more selectively. For the systems landscape that means separate truths about the same book rather than twice the work.
Three questions that appear in none of the documents
Three points cannot be answered from the published material and therefore belong at the top of any migration list. First, it is open which calendar week the first report under the new package covers and how the current week is treated, the one the switch falls into. Second, nothing has been published on whether and until when a test environment for uploads against the new package is available. Third, the question of the right report status in the event of a rejection is provided for in the validation rules but not answered for the moment of the switch.
All three sit with the trading venue or with the supervisor, and all three cost one email today. Asked on reporting day, they come too late.
On 27 March the cancellation came five days before the start, and it came from the authority. This time the date has been confirmed since 14 August, the reporting instructions are out, the validation rules are published, and a grace period is not among them. Whatever still goes wrong on 3 September will go wrong in house.
Recommendations
The first three points are addressed to the reporting team of the trading venue, the one that files the report itself. Members and participants who do not file themselves should move point four forward and put the remaining questions to their own venue.
Before 3 September: the split into risk-reducing and other positions has to produce the total on display for every category and every measure. This is the validation rule most likely to bite where the split logic is new, and it bites in sixty places per contract and week. A test run on last week’s figures shows in minutes whether the sums hold.
This week: the admissible statuses are new report, amendment and cancellation. Which one applies in the event of a rejection should be written down rather than decided on reporting day. That includes who takes the decision and within what window.
Now: the reporting package carries version 2.0, the ISO message stays at auth.051.001.01 in version 01. Raise a message-level version check to 2.0 and you produce rejections at file level.
Today: the first reporting period, the test environment and the handling of the switching week are not published. A short enquiry to the operator costs little and keeps the clarification off the morning of reporting day. With no grace arrangement announced, the first report is the first real test.
Glossary
COMB and FUTR: the two admissible values in the report type field. COMB combines options and futures, FUTR carries futures alone. They decide which of the two weekly reports is at hand.
NEWT, AMND, CANC: the three admissible report statuses, meaning new report, amendment and cancellation. Every correction to an already submitted report runs through them.
auth.051.001.01: the identifier of the underlying ISO 20022 message. It sits in the submission itself and is to be kept apart from the version of the document package.
Risk-reducing: positions that directly reduce risks relating to the commercial activity. Per category and measure they will now be reported separately from all other positions.
Christian Schablitzki
Strategy & Management Consultant · Agentic AI expert for financial institutions
More than 20 years in investment banking and derivatives trading, followed by over 10 years advising financial institutions. Currently Partner at Infosys Consulting in Germany. Certified in Google AI, Generative AI Leader (Google Cloud) and IBM RAG and Agentic AI.
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