From Submission to Assurance: The Path to Proving Transaction Reporting Accuracy.
Key Takeaways
- Regulatory reporting does not end at submission. Firms must be able to demonstrate that submitted transaction data remains complete, accurate and consistent with their internal books and records.
- Reconciliation should cover the full transaction lifecycle. Controls should identify missing reports, unmatched external records, critical-field discrepancies and matured or terminated transactions that remain incorrectly reported as open.
- A reconciliation process must lead to remediation. Firms should document how breaks are identified, investigated, aged, escalated, corrected and prevented from recurring.
- Global reporting structures increase reconciliation risk. Delegated reporting arrangements, multiple trade repositories and jurisdiction-specific reporting logic can create gaps between internal records and externally reported data.
- Reconciliation must be risk-based and repeatable. Its scope and frequency should reflect transaction volumes, asset classes, reporting regimes and changes to the firm’s technology or operating model.
Transaction Reporting Reconciliation: Regulatory Expectations Across G20 Regimes
For firms subject to G20 transaction reporting regimes, post-submission reconciliation is becoming a core regulatory control. Regulators increasingly expect firms to demonstrate that reported transaction data remains complete, accurate, and consistent with internal books and records throughout the reporting lifecycle.
Regulatory Developments
Supervisors are placing greater emphasis on controls that verify trade repository and regulator-facing data after initial submission.
Recent action by the Australian Securities and Investments Commission against Deutsche Bank illustrates this approach. ASIC alleged that the bank misreported more than 260,000 over-the-counter derivative transactions and failed to take reasonable steps to ensure the data remained complete, accurate and current.
The alleged failures included 20,483 outstanding transactions and 244,091 terminated or matured transactions across 208 business days. This demonstrates that stale lifecycle records are a material control issue. Transactions that have matured or terminated but remain incorrectly reported as open can distort the regulator’s view of market exposure and activity.
Similar expectations apply in the United States, where the Commodity Futures Trading Commission continues to focus on data quality, reporting errors, and supervisory controls. In 2024 alone, the CFTC has actively imposed over $60 million in enforcement fines, across six swap dealers, for data quality issues, timeliness, and completeness issues. In 2025, the CFTC maintained its enforcement focus by imposing an additional penalty for swap data reporting violations involving valuation data.
The UK Financial Conduct Authority, for example, has released several publications relating the importance of reconciliation. The regulator is clear in that they expect firms to reconcile front-office records against data submitted through the Market Data Processor and to correct and back-report identified errors. The broader regulatory principle is clear: reporting obligations are not satisfied when a file is transmitted. Firms must also evidence that submitted data continues to reflect the underlying transaction population.
Control Implications
Historically, many firms have prioritised submission timeliness over post-submission data integrity. This approach is increasingly difficult to defend because reconciliation is the primary control used to demonstrate that the reporting framework is operating effectively.
Reporting failures may include:
- Internal open positions missing from the regulatory or trade repository population.
- External singletons that appear open in the repository but cannot be supported by internal records.
- Transactions present in both populations with mismatched critical fields, including direction, notional, counterparty, execution details, or lifecycle status.
- Matured or terminated transactions that remain reported as open or have not been updated correctly.
These risks are amplified for global firms using delegated reporting arrangements, multiple trade repositories and jurisdiction-specific reporting logic.
Recommended Framework
Firms should implement rolling, risk-based reconciliation across both open and closed transaction populations. The control framework should include documented break identification, ageing, materiality assessment, root-cause analysis, remediation ownership, escalation, and re-reporting governance. Many firms, absent prescriptive guidance from regulator, adopt a 30-day rolling reconciliation for G20 regimes. For MIFID, in UK and EU, firms adopt a varied approach ranging from weekly, monthly and quarterly reconciliation that is dependent upon trade volume, asset classes and technology changes.
The objective is not simply to identify exceptions, but to demonstrate that reporting discrepancies are detected, investigated, corrected and prevented from recurring. Across G20 regimes, a documented and consistently executed reconciliation process is increasingly a minimum supervisory expectation.
How Qomply can help
Qomply’s Regulatory Reporting Hub combines regulatory expertise with AI, automation and data analytics to deliver scalable, audit-ready reporting intelligence that reduces errors, lowers remediation costs, and minimises operational and regulatory risk.
Covering regimes including MiFIR, EMIR Refit, SFTR, CFTC, CSA, MAS, ASIC and HKMA, Qomply also offers a fully managed service and operates globally from London.
Frequently asked questions
Transaction reporting reconciliation is the process of comparing a firm’s internal books and records with transaction data submitted to a regulator or trade repository. It helps firms identify missing transactions, unsupported external records, mismatched reporting fields and incorrect lifecycle statuses.
Submitting a transaction report does not, by itself, demonstrate that a firm’s reporting is complete and accurate. Post-submission reconciliation helps confirm that the data received by the regulator or trade repository continues to match the firm’s underlying transaction population throughout the reporting lifecycle.
Reconciliation can identify internal transactions missing from regulatory data, external records that cannot be matched to internal systems, discrepancies in critical reporting fields and matured or terminated transactions that remain incorrectly reported as open.
A reconciliation framework should cover open and closed transaction populations and include break identification, ageing, materiality assessment, root-cause analysis, remediation ownership, escalation procedures and re-reporting governance. Firms should also document how discrepancies are investigated, corrected and prevented from recurring.
The appropriate frequency depends on the applicable reporting regime, transaction volumes, asset classes, risk exposure and the complexity of the firm’s reporting infrastructure. Reconciliations should be performed regularly and frequently enough to identify and remediate reporting errors promptly.
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