On 3 September 2026 the European Securities and Markets Authority (ESMA) moves weekly position reporting for commodity derivatives onto a revised package. The authority confirmed the date on 14 August and published the updated reporting instructions, the technical specifications and the validation rules at the same time.
The date will feel familiar to some, and rightly so. Go-live was originally set for 1 April 2026. On 27 March, five days before launch, ESMA withdrew it, citing problems in the final testing phase that required further corrective action to secure system stability and data quality. That history belongs in any assessment of the current position: the date is confirmed, and it has been confirmed before.
What: revised package for aggregated weekly position reporting under Art. 58 (1) a of the Markets in Financial Instruments Directive II (MiFID II)
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 centrally and makes the checked data available to national competent authorities
German provision: section 57 WpHG (titled „Position reporting; empowering provision")
Legal basis of the reform: Directive (EU) 2024/790 of 28 February 2024, implemented through the ESMA final report of 16 December 2024
Which reporting chain is affected, and which is not
What gets confused on this topic is usually the addressee. Art. 58 MiFID II sets out two separate reporting routes, and only one of them switches on 3 September.
What is affected is the aggregated weekly report under Art. 58 (1) a. The venue operator submits it to ESMA. The authority checks it, publishes it centrally and makes it available to national supervisors. The venue also publishes the report itself.
What is not affected is the daily report under Art. 58 (1) b. Here 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 and reports to the German Federal Financial Supervisory Authority (BaFin), not to ESMA.
Both chains sit in section 57 WpHG. For planning inside an institution it pays to be clear about which interface is being touched. A reference to section 54 WpHG, which appears from time to time, points elsewhere: that provision governs position limits.
What changes in the package
ESMA refers in its notice to an XML schema at version 2.0. One point is worth spelling out for practitioners: the version number labels the document package. The underlying ISO 20022 message remains auth.051.001.01 at version 01. Anyone who has implemented a check on the message version should know that before touching it.
Four changes matter in substance.
First, two weekly reports instead of one. The report type field now distinguishes between a report combining options and futures (value COMB) and one covering futures alone (value FUTR). One delivery becomes two.
Second, five categories of position holder, each split long and short. They cover investment firms and credit institutions; investment funds; other financial institutions including insurers, reinsurers and institutions for occupational retirement provision; commercial undertakings; and, for emission allowance derivatives only, operators with obligations under the emissions trading system.
Third, the split by purpose. Each of the three measures, namely the number of positions, the change against the previous report and the share of open interest, is now reported per category, split between positions directly reducing risk in connection with commercial activity and all others. The two parts must sum to the total reported; a dedicated validation rule checks it.
Fourth, definitions at the edges. Emission allowances in the spot market drop out of position reporting. Derivatives on emission allowances stay in and form the fifth category. For energy derivatives the quantity notations are harmonised: lots, megawatt hours, million British thermal units and therms.
Where a submission gets rejected
Validation applies at two levels. At file level a delivery fails on a schema mismatch, a decompression error or an incorrect version of the message identifier, among other causes. At content level the rules 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 totals and match the venue identifier against the stored table.
Permitted report statuses are a new submission (NEWT), an amendment (AMND) and a cancellation (CANC). In practice the way back from a rejected report runs through one of those three, and it is worth deciding before 3 September which one applies in the event of failure.
No grace period has been communicated so far. Neither the ESMA documents nor BaFin's guidance names a transitional arrangement for the switch. That is not a statement about how supervisors will respond in an individual case; it records that no arrangement has been published.
The reporting thresholds
The thresholds for publication are unchanged. A report is published where at least twenty open position holders are active in a contract at a venue and the absolute gross long or short amount exceeds four times the deliverable supply. The second condition falls away for contracts without physical delivery and for emission allowance derivatives.
One detail carries weight for analysis: where fewer than five position holders are active in a category, their number is not published. Anyone using the published data for market analysis will therefore find gaps at exactly those points.
How this relates to position limits
Position reporting is a transparency instrument. Setting and monitoring limits runs through a separate legal act and through BaFin general rulings, most recently that of 10 February 2026.
The revised Art. 57 (8) MiFID II leaves the four control powers of trading venues unchanged in substance. They remain monitoring, requesting information, ordering a reduction or termination of positions, and a temporary obligation to provide liquidity. What is new is the scope alone: those controls now also apply to venues trading emission allowance derivatives.
A glance at London
For institutions authorised in both the European Union and the United Kingdom the comparison repays attention, because the two regimes are moving apart. In its policy statement of February 2025 the Financial Conduct Authority shifted responsibility for position limits onto the venues themselves, with final rules in force since 6 July 2026. Limits there now apply only to a narrower set of contracts deemed critical.
The two are heading in opposite directions. The European Union deepens the reporting duty while the United Kingdom narrows the limit duty and moves it operationally to the venue. For houses under both regimes that means two regimes running side by side from September.
What is needed on 3 September
Three questions cannot be answered from the published material and therefore belong at the top of any switching list. First: which calendar week does the first report under the new package cover, and how is the week in which the switch falls treated? Second: is a test environment available for uploads against the new package, and until when? Third: which report status applies if the first submission is rejected?
All three are for the venue or the supervisor to answer. Asked on the reporting day, they come too late.
Recommendations
The first three points address the reporting team at the venue, which submits the report itself. Members and participants that do not report directly should move point four forward and press the venue for the remaining answers.
Before 3 September: The split between risk-reducing and other positions has to reconcile to the reported total, per category and per measure. That is the validation rule most likely to bite where the split logic is new. A test run on last week's figures shows within minutes whether the totals hold.
This week: The permitted statuses are new submission, amendment and cancellation. Which one applies on rejection should be written down rather than decided on the reporting day, along with who decides and within what window.
Now: The reporting package carries version 2.0; the ISO message stays at auth.051.001.01 version 01. Anyone who has implemented a version check at message level and raises it to 2.0 will produce rejections at file level.
Today: The first reporting period, the test environment and the treatment of the switching week are not published. A short enquiry to the operator costs little and means the clarification does not have to happen on the morning of the reporting day. With no grace period announced, the first report is the first real test.
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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