ESMA: weekly reporting of positions in commodity derivatives

ESMA also maintains a file/content error list

MiFID II requires trading venues on which commodity derivatives (as well as derivatives on emission allowances) are traded to make public a weekly report of aggregate positions broken down by categories of persons.

The weekly report includes, inter alia, the number of long and short positions and the changes compared with the previous report. The publication obligation applies once minimum thresholds for the number of persons and the size of open positions are exceeded.

The aforementioned person comprise investment firms or credit institutions, investment funds (UCITS/AIFs), other financial institutions, commercial undertakings, and- for emission allowances- operators with compliance obligations under Directive 2003/87/EC.

What ESMA has issued. ESMA has released version 2.0 of the Interface Specifications Document- Commodities Derivatives Weekly Position Reporting, which standardises the format, data fields, and transmission rules for position data to enable centralised publication in accordance with Article 58 MiFID II. The detailed specifications are based on the ISO 20022 XML standard.

Key elements of ESMA’s updated instructions (version 2.0)

Frequency and reporting period

• Cadence: a file is submitted once per week before the agreed cut-off time.
• Date scope: the file covers the previous Monday–Friday reporting period.

Record statuses and versioning

• Each record must carry one of the following statuses: NEWT (new), AMND (amend) or CANC (cancel). This enables post-publication corrections without duplication of entries.

Business and quality validations

• Uniqueness: a report cannot be re-submitted with the same combination of venue product code, NEWT status and the date to which the report refers.
• Date integrity: the Date to which the Weekly Report refers must be earlier than the processing date and not earlier than 31-12-2017; the Date and time of Publication must be a valid date/time.
• Arithmetic integrity: the sum of Risk reducing directly related to commercial activities and Other must equal Total; Long/Short fields must be numeric.
• ESMA also maintains a file/content error list (e.g., schema non-compliance with XML, publication date earlier than 31-12-2017, non-numeric values).

Mandatory data set

The instructions enumerate a complete set of mandatory fields for each file, including: name and identifier of the trading venue, the date to which the report refers, the date and time of publication, instrument name, venue product code, report status, report type, number of positions, nominal size of positions, changes versus the previous report.

Additionally, also: the number of persons holding positions in commodity derivatives or derivatives on emission allowances by the nature of their main business, broken down by categories of persons. All fields are mandatory.

Transmission standard and technical structure

Files must use ISO 20022 XML, with specified XPath locations for individual fields. The instructions also set a file-naming convention (e.g., DATPOS for inbound position files and FDBHUB for HUBEX feedback files), which harmonises the operational flow of data.

Publication process and access for authorities

Following successful validation and publication, the national competent authority (in Poland, KNF) should retrieve a copy of the published file from ESMA’s website (for confirmation and archiving purposes).

Alignment with MiFID II

• Personal and temporal scope: trading venues must publish weekly position reports; in parallel, at the request of the competent authority they must communicate daily breakdowns of positions for all persons (including members/participants and their clients).
• Publication conditions: the obligation applies to venues where minimum thresholds for the number of persons and open positions are exceeded (thresholds further specified in technical measures).
• Categories of persons: the report covers the categories listed in Article 58(4) (investment firms/credit institutions; investment funds; other financial institutions; commercial undertakings; and, for emission allowances, operators with compliance obligations), with a distinction between positions that in an objectively measurable way reduce risks directly related to commercial activities and other positions.
• Centralised publication: weekly reports are communicated to ESMA, which performs centralised publication.

Core takeaways from ESMA’s new instructions

1. Clarified timetable and “weekly reporting period”- explicit confirmation that aggregation covers Monday- Friday, with submission before the agreed cut-off; this removes ambiguity around weekends and public holidays.
2. Tighter anti-duplication and date controls- the system rejects duplicate or time-inconsistent submissions; minimum historic dates are standardised to align with MiFID II implementation.
3. Clear lifecycle statuses (NEWT/AMND/CANC)- facilitate post-publication corrections and proper record replacement.
4. Complete mandatory field list- including reconciliation of risk-reducing/other to total and numeric validation of long/short values.
5. Format standardization- confirmation of ISO 20022 XML and key XPath references, reducing cross-venue implementation divergence.
6. File naming and feedback files- harmonised categories (e.g., DATPOS, FDBHUB) support automation and faster error diagnosis.

Why is this important for investment firms?

For investment firms and other reporting entities, the harmonised format and validation regime reduces integration risk and cross-venue discrepancies, thereby lowering the likelihood of ESMA rejections.

The updated instructions are directly linked to the obligations arising under Article 58 MiFID II.

Don’t risk making mistakes in your reporting- the updated ESMA guidelines are now in effect!

Ensure compliance with Article 58 of MiFID II- check whether your reports meet the new technical and validation requirements. Implementing the update is not just a formality, it is a real reduction in the risk of rejection by ESMA.
Don’t wait- contact our team of experts!