Nieuw boetebeleid voor niet-gemelde tekortkomingen in transactierapportages

This policy clarifies the regulator's expectations and the consequences for firms that identify reporting shortcomings but do not notify the AFM. For compliance teams, the key message is that detection alone is not enough—firms must have robust processes to identify, assess, and report transaction reporting errors to the regulator. The AFM's move signals a tougher stance on reporting failures and a focus on proactive disclosure.

Firms should review their transaction reporting frameworks, including data quality controls, exception monitoring, and escalation procedures. Where deficiencies are found, they should be documented and reported promptly to the AFM. The policy also increases the risk of fines for non-disclosure, making it essential for senior management and compliance functions to understand their obligations.

Opportunities exist for firms that invest in reporting technology and controls: they can reduce regulatory risk, improve data integrity, and demonstrate good governance. RegTech providers may see demand for solutions that automate detection and reporting of transaction reporting errors. Overall, this is a significant compliance development for investment firms and those with MiFIR reporting obligations.