Responding to this paper
ESMA invites comments on all matters in this paper and in particular on the specific questions summarised in Annex 1. Comments are most helpful if they:
- respond to the question stated;
- indicate the specific question to which the comment relates;
- contain a clear rationale; and
- describe any alternatives ESMA should consider.
ESMA will consider all comments received by 21 September 2025.
All contributions should be submitted online using the provided reply form in .docx format.
Publication of responses
All contributions received will be published following the close of the consultation, unless you request otherwise. Please clearly and prominently indicate in your submission any part you do not wish to be publicly disclosed. A standard confidentiality statement in an email message will not be treated as a request for non-disclosure. A confidential response may be requested from us in accordance with ESMA’s rules on access to documents. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by ESMA’s Board of Appeal and the European Ombudsman.
Data protection
Personal data contained in the file will be published as submitted. If you don't wish such personal data to be publicly available, you should not include personal data within the document you upload to a public consultation. Alternatively, you may choose the option not to have your response published on the ESMA website. For further details on data processing, please refer to the record register.
Information on data protection can be found under the heading ‘Legal Notice and Data protection’.
Who should read this paper?
This Discussion Paper will be of interest to stakeholders involved in supervisory and statistical reporting. In particular, it targets alternative investment fund managers (AIFMs), UCITS management companies, UCITS investment companies, and branches of EU and non-EU fund managers. It is also relevant to industry associations as well as any other entities involved in the reporting process or affected by its outcomes.