Résultat de l’exercice de contrôle des indicateurs de la qualité des données SFTR de 2025 (uniquement en anglais)
La CSSF informe le marché concernant les résultats de l’exercice de contrôle des indicateurs de la qualité des données SFTR de 2025
In 2025, ESMA and NCAs applied the SFTR framework and ran a data quality review exercise based on the pre-defined SFTR Data Quality Indicators (hereafter ‘2025 SFTR DQI exercise’).
Similarly to other NCAs, the CSSF reviewed the data and contacted the Entities Responsible for Reporting (ERRs) established in Luxembourg with the largest amounts of data quality issues to correct or justify the values reported.
Following exchanges with the selected ERRs, the following causes for data quality issues have been identified:
- Termination events not being submitted,
- Incorrect values submission in numeric fields,
- Incorrect reporting of the sign of the transaction (e.g. +100 vs -100),
- Inconsistent reporting of Variation margin and collateralisation fields.
In order to avoid the above-mentioned issues, the CSSF recommends all counterparties, in particular those involved in the 2025 SFTR DQI exercise, to implement the necessary controls such as, but not limited to:
- Ensuring all automated processes are working correctly on a regular basis,
- Performing reconciliations between the internal systems, counterparties, service providers and the TR-reported data,
- Ensuring that service providers perform their tasks correctly.
Additionally, the CSSF wishes to reiterate the fact that validation rules are not intended to identify all potential errors and omissions. Therefore, the fact that a transaction report was accepted by the TR does not necessarily mean that the submitted report contains complete and correct information.
Counterparties are strongly encouraged to leverage on the data required by regulatory reporting regimes in their own internal processes (e.g. risk management and compliance control). In doing so, counterparties will have the appropriate incentives to report accurate data and will be in a position to better exploit the benefits of consistent data reporting across the regulatory frameworks.