Commodity Derivatives Position Reporting: ESMA’s 3 September Go-Live

On 14 August 2026 ESMA confirmed that the reworked weekly commodity derivatives position reporting framework goes live on 3 September 2026. From that date, an investment firm or market operator operating an EU trading venue whose relevant contract is subject to the Article 58 weekly-reporting obligation must submit the weekly report to ESMA using the v2.0 ISO 20022 XML specification; Article 83 minimum thresholds still determine when the weekly-reporting obligation applies. A submission built to last year’s structure will fail validation at the door.

The legal duty itself has been in force for years. It sits in Article 58 of MiFID II (Directive 2014/65/EU) and has applied since 2018. What changes on 3 September is the technical channel and the content of the return: two weekly reports where options are traded, the exclusion of spot emission allowances, revised field definitions, and updated validation rules. ESMA’s reporting instructions (ESMA65-955014868-14991) and XML schema v2.0 (ESMA65-955014868-14993) are the technical interface specification for the 3 September cutover; legal scope, thresholds and confidentiality requirements must still be read from the governing MiFID II and Article 83 text.

This lands on reporting teams and trading-venue operations. For an in-scope weekly report, the v2.0 instructions require submission through HUBEX before the agreed cut-off time for the previous Monday-Friday reporting period.

Related reading: MiFIR Transaction Reporting

The go-live calendar, and what each date fixes

Position reporting for commodities has three layers stacked on top of each other: the Level 1 obligation in MiFID II, the 2024 review that changed that obligation, and the Level 2 technical standards that tell you how to file. The dates that matter for the September cutover:

• 28 February 2024: Directive (EU) 2024/790, the directive amending MiFID II, was adopted.
• 8 March 2024: it was published in the Official Journal.
• 29 September 2025: deadline for Member States to bring into force the laws, regulations and administrative provisions necessary to comply with Directive (EU) 2024/790.
• 16 December 2024: ESMA published its Final Report on the amendments to the commodity derivatives technical standards (ESMA74-2134169708-7577), carrying the revised ITS and the technical advice on Article 83.
• 14 August 2026: ESMA confirmed the go-live and released the v2.0 reporting instructions and schema.
• 3 September 2026: go-live. First weekly submissions in the v2.0 XML schema.

Directive (EU) 2024/790 required Member States to bring transposition measures into force by 29 September 2025. ESMA subsequently postponed the technical rollout of the updated weekly-reporting arrangements and on 14 August 2026 confirmed 3 September 2026 as the revised go-live.

Who submits the weekly commodity derivatives position report

Article 58(1)(a) puts the weekly report on the operator of the trading venue. In ESMA’s language for this system the reporter is the submitting entity: an investment firm or a market operator running a venue on which commodity derivatives or derivatives on emission allowances trade. That covers regulated markets, MTFs and OTFs. The obligation follows the venue operator: where the entity operating the MTF is an investment firm or market operator within Article 58(1), it is the submitting entity for that venue.

The flow is centralised. Submitting entities upload the aggregated position data to ESMA through the HUBEX file-transfer system on the ESMA network; ESMA validates it, publishes the aggregate on its public website, and makes the validated files available to national competent authorities to download. The weekly report groups position holders into the categories set by Article 58(4): investment firms and credit institutions, investment funds, other financial institutions and commercial undertakings, with the additional emission-allowance-compliance-operator category applying in the case of derivatives on emission allowances. Subject to the Article 83(3) confidentiality suppression for categories with fewer than five position holders, the report contains long and short positions, the change since the previous week, the share of open interest, and the number of holders by category.

Two adjacent obligations sit close to this one. The daily complete breakdown of positions under Article 58(1)(b) goes to the competent authority, not into the weekly ESMA feed. And investment firms trading commodity derivatives or derivatives of emission allowances outside a trading venue provide, on at least a daily basis, the competent authority specified in Article 58(2) with a complete breakdown of their positions in economically equivalent OTC contracts and those of their client chain, as required under Article 58(2). The 3 September go-live concerns the weekly aggregated report to ESMA. The daily returns keep their own channels.

What the 2024 MiFID II review actually changed

Directive (EU) 2024/790 changed Article 58 by removing spot emission allowances from position reporting while leaving derivatives on emission allowances in scope, and by requiring two weekly reports where options are traded, one of which excludes options.

Those two changes could not be delivered in the reporting layer without touching the Level 2 standards. The review reopened the implementing technical standards on the format of position reports, Commission Implementing Regulation (EU) 2017/1093 (ITS 4 in ESMA’s shorthand), and Article 83 of Commission Delegated Regulation (EU) 2017/565, the article that carries the reporting thresholds. ESMA consulted on the draft Level 2 changes in May 2024 and in December 2024 submitted amended draft technical standards to the Commission for adoption. ESMA’s v2.0 instructions and schema implement its operational reporting approach.

A point worth keeping straight: the weekly commodity derivatives position report runs under MiFID II Article 58. It reports aggregate positions by category of holder to ESMA once a week, whereas the transaction-level reporting of derivatives to trade repositories runs on a separate track under EMIR. If your team also files under EMIR, treat the two as different pipelines with different content, timing and recipients; our EMIR reporting guide covers that regime on its own terms.

The second weekly report: COMB and FUTR

The two-report rule is the change most likely to break an existing extract. ESMA’s v2.0 reporting specification carries a Report type field with COMB for the report combining futures and options and FUTR for the report excluding options. ESMA’s December 2024 Final Report presented the corresponding ITS 4 change as a draft amendment submitted to the Commission for adoption. A venue that lists both futures and options on a commodity, and that meets the threshold, publishes both: one COMB report and one FUTR report for that contract. A venue that lists only futures keeps filing a single report.

The treatment of options differs between the two. In the COMB report, option contracts are included in the aggregation and reported on a delta-equivalent basis. In the FUTR report, option contracts are left out of the aggregation entirely. Futures positions are reflected in both reports, while option positions are included only in COMB on a delta-equivalent basis; FUTR excludes options.

In its December 2024 Technical Advice, ESMA stated that the Article 83 thresholds should be assessed on futures and options combined and that, where the combined basis meets the thresholds, both weekly reports should be published. The current Article 83 text located for this review does not contain that added futures-and-options-combined wording, so this treatment should be identified as ESMA’s Technical Advice rather than as enacted Article 83 text.

The v2.0 fields that changed, and the format that did not

The schema stays ISO 20022 XML. That is worth stating plainly because ESMA’s May 2024 consultation proposed moving the weekly and daily reports from XML to JSON, and the December 2024 Final Report removed that proposal from the draft ITS. So the format your pipeline targets on 3 September is still XML, under the FinInstrmRptgCmmdtiesDerivsWklyRpt message, and there is no new JSON interface to build.

Inside the message, several fields move. Position quantities in electricity and natural gas derivatives are now expressed in units of the underlying, such as megawatt hours, therms or million British thermal units, while positions in other commodity derivatives stay in lots. The notation field accordingly accepts LOTS, MWHO, THMS and MBTU. The report status field drives what you are doing to a record: NEWT for a new report, AMND to amend, CANC to cancel. Each commodity report still splits positions into those that reduce risks directly related to commercial activities and all other positions, and the validation checks that the risk-reducing figure plus the other figure equals the total. Where fewer than five position holders are in a category, Article 83(3) requires the aggregate long and short positions, changes since the previous report, percentage of total open interest and number of holders for that category not to be published. ESMA’s v2.0 instructions separately state that the number-of-holders field is populated with a full stop in that case.

ESMA’s December 2024 draft ITS also proposed changes to the daily-report identifier fields, including an LEI policy clarification and clearer identifier wording. Those identifier changes concern Annex II for daily reports, not the weekly v2.0 aggregated-report field set.

Spot emission allowances leave the report; derivatives remain in scope

Spot emission allowances come out of Article 58 position reporting; derivatives on emission allowances remain in scope. ESMA’s draft ITS removes spot-emission-allowance references from the weekly report, while the proposed deletion of the EMIS code concerns the daily-report fields in Annex II, not a weekly v2.0 field.

The revised Article 57 extends position management controls to venues trading derivatives on emission allowances, including monitoring of open-interest positions. ESMA’s December 2024 package separately proposed amendments to Delegated Regulation (EU) 2022/1299 concerning accountability levels for those venues. Reporting scope narrowed while control scope widened, on the same instruments, in the same package. Treat the emission-allowance line in your mapping as two separate questions, one for the weekly report and one for position management, because the answers now point different ways. The commodity-derivative position-limits and management regime sits alongside this; the commodity derivative position limits notification process shows how the control side is handled at national level.

Thresholds: when a weekly report is actually due

Not every in-scope contract generates a weekly report. Article 83 of Delegated Regulation (EU) 2017/565 sets a threshold of 20 open position holders and a second threshold under which the absolute gross long or short volume of total open interest must equal or exceed 10,000 lots. However, Article 83(1) expressly provides that the 10,000-lot threshold does not apply to emission allowances or derivatives thereof; following the removal of spot emission allowances from Article 58 position reporting, that exception remains relevant to derivatives on emission allowances. Delegated Regulation (EU) 2021/527 replaced the former deliverable-supply test with the 10,000-lot open-interest threshold.

Two practical wrinkles sit on top. ESMA’s December 2024 Technical Advice states that the thresholds should be assessed on futures and options combined and that both reports should be published where that combined basis meets the conditions. The current Article 83 text located for this review does not contain that combined-basis wording. ESMA addressed that conversion issue in Q&A ESMA_QA_2439 on 13 February 2025. For the 10,000-lot threshold, ESMA uses the monthly contracts in which most trading activity is concentrated as the baseline: 10,000 lots correspond to 7,200,000 MWh for gas and base-load power and 2,640,000 MWh for peak-load power; the Q&A also provides MMBTU and therm conversions for gas and base-load power. For the wider gas-market reporting picture, our note on gas derivatives under EMIR and REMIT maps the neighbouring obligations.

Build errors to catch before the first v2.0 submission

The failure modes for this cutover cluster in a few places. The main stale-build checks are the Article 83 threshold test, exclusion of spot emission allowances from the weekly extract and the two-report logic where options are traded. The EMIS code is a daily-report field in the existing ITS architecture and should not be treated as a weekly v2.0 field. The second is the unit mismatch: ESMA’s revised reporting approach uses units of the underlying for power and natural-gas positions rather than lots. The published v2.0 field validation permits LOTS, MWHO, MBTU and THMS as notation values; the published validation table does not identify a separate rejection rule for an incorrect instrument-to-unit pairing. The third is the internal arithmetic, where the risk-reducing and other figures do not sum to the stated total, a check ESMA runs on ingest.

Timing is the last trap. The weekly report references the Friday of the calendar week, and the file has to reach ESMA before the agreed cut-off. For contracts to which both Article 83(1)(a) and (b) apply, the first weekly report must be published as soon as feasibly practical and in any event no later than three weeks after the thresholds are first triggered, and publication continues for three months after those conditions cease to be met. For derivatives on emission allowances, Article 83(1)(b), the 10,000-lot threshold, does not apply. Because Article 83(1)(b) does not apply to derivatives on emission allowances while Article 83(4) is drafted by reference to both Article 83(1)(a) and (b), the current text reviewed does not expressly state the first-publication timing for that one-threshold case. ESMA’s 14 August 2026 go-live notice states that v2.0 applies from 3 September 2026 but does not establish a separate deferral for newly qualifying contracts. The safest approach is a full dress rehearsal against the v2.0 schema well before 3 September. Teams that also handle MiFIR returns will recognise the pattern from ESMA’s transaction reporting simplification work, where format changes and validation rules move together.

Frequently Asked Questions

Does the weekly commodity derivatives position reporting obligation start on 3 September 2026?

No. The weekly reporting duty under Article 58 predates the 3 September 2026 technical cutover. From 3 September ESMA applies the v2.0 ISO 20022 XML specification and its updated reporting requirements; the revised Article 58 requires two weekly reports where options are traded and excludes spot emission allowances while retaining derivatives on emission allowances in scope.

Our venue lists only futures on a commodity. Do we produce two reports?

No. The two-report requirement applies only where a venue lists both futures and options on the commodity and the Article 83 thresholds are met. A futures-only venue continues to file a single report for that contract.

How are options handled differently in the COMB and FUTR reports?

In the COMB report, options are included in the aggregation on a delta-equivalent basis. In the FUTR report, options are excluded from the aggregation. Futures positions are reflected in both reports, while option positions are included only in COMB on a delta-equivalent basis and are excluded from FUTR.

We report positions in a power contract. Do we still use lots?

Positions in electricity and natural gas derivatives are expressed in units of the underlying, such as megawatt hours, therms or million British thermal units, using the MWHO, THMS or MBTU notation. Lots remain the unit for other commodity derivatives. ESMA clarified how the 10,000-lot threshold translates into underlying units for energy derivatives in Q&A ESMA_QA_2439 on 13 February 2025, including MWh, MMBTU and therm conversions.

Is the reporting format moving to JSON?

No. ESMA consulted on moving from XML to JSON and decided not to proceed. The weekly and daily reports remain in ISO 20022 XML, so the go-live is a schema version change within XML.

What happened to emission allowances in the report?

The revised Article 58 removes spot emission allowances from position reporting while retaining derivatives on emission allowances in scope. ESMA’s draft ITS removes spot-emission-allowance references from the weekly report; its proposed deletion of the EMIS code concerns the daily-report fields. Separately, Article 57 extends position management controls to venues trading derivatives on emission allowances.

When exactly does a newly qualifying contract have to appear?

For contracts to which both Article 83(1)(a) and (b) apply, the first weekly report is due as soon as feasibly practical and no later than three weeks after the thresholds are first triggered, and publication continues for three months after those conditions cease to be met. For derivatives on emission allowances, Article 83(1)(b) does not apply.

Related Articles

• MiFIR Transaction Reporting: how transaction-level reporting under MiFIR Article 26 works and where it interacts with the daily position breakdown.
• EMIR Reporting Explained: the separate derivative reporting regime to trade repositories, and how it differs from MiFID position reporting.
• CSSF Commodity Derivative Position Limits Notification: how the position-limits and management side of the commodity regime is handled at national level.
• Gas Derivatives Under EMIR and REMIT: the neighbouring reporting obligations for wholesale energy and gas contracts.
• ESMA Transaction Reporting Simplification: the wider direction of travel across EMIR, MiFIR and SFTR reporting.
• UK MiFIR Transaction Reporting Reform: how the UK is diverging on its own reporting rules after Brexit.

Key Takeaways

• From 3 September 2026, weekly commodity derivatives position reports must reach ESMA in the v2.0 ISO 20022 XML schema; the old layout is no longer accepted.
• The weekly reporting duty remains in Article 58 of MiFID II, but Article 58 itself was amended by Directive (EU) 2024/790; the 3 September cutover is ESMA’s technical implementation of the updated reporting framework.
• Venues listing both futures and options on a commodity file two weekly reports: COMB (options included, delta-equivalent) and FUTR (options excluded). Futures-only venues file one.
• Article 83 currently sets a 20-open-position-holder threshold and a 10,000-lot gross long or short open-interest threshold, but the 10,000-lot threshold does not apply to derivatives on emission allowances; ESMA’s December 2024 Technical Advice states that the applicable thresholds should be assessed on a futures-and-options-combined basis. The former deliverable-supply test was replaced in 2021.
• Power and natural gas positions are reported in units of the underlying (MWh, therm, MMBtu); other commodities stay in lots.
• Spot emission allowances leave Article 58 position reporting, while derivatives on emission allowances remain in scope. ESMA’s draft ITS proposes deletion of the EMIS code from the daily-report fields, and Article 57 extends position management controls to venues trading derivatives on emission allowances.
• The format stays XML; the consulted move to JSON was dropped.
• Run a full validation rehearsal against the v2.0 schema before 3 September. For contracts to which both Article 83(1)(a) and (b) apply, Article 83(4) requires the first weekly report as soon as feasibly practical and no later than three weeks after those thresholds are first triggered; the current text reviewed does not expressly state an equivalent first-publication deadline for derivatives on emission allowances, for which Article 83(1)(b) does not apply.

Sources and References

• Directive 2014/65/EU (MiFID II), Article 58 and Article 57: EUR-Lex
• Directive (EU) 2024/790 amending MiFID II (adopted 28 February 2024, OJ 8 March 2024): EUR-Lex
• Commission Implementing Regulation (EU) 2017/1093 (ITS on the format of position reports, OJ L 158, 21.6.2017): EUR-Lex
• Commission Delegated Regulation (EU) 2017/565, Article 83 (position reporting thresholds): EUR-Lex
• Commission Delegated Regulation (EU) 2021/527 amending Article 83 (10,000-lot threshold, OJ L 106, 26.3.2021): EUR-Lex
• ESMA Final Report on the amendments to certain technical standards for commodity derivatives (ESMA74-2134169708-7577, 16 December 2024): ESMA
• ESMA news, ESMA confirms go-live for weekly commodity derivatives position reporting (14 August 2026): ESMA
• ESMA Commodities Derivatives Weekly Position Reporting, reporting instructions (ESMA65-955014868-14991): ESMA
• ESMA Q&A ESMA_QA_2439, energy derivatives open-interest threshold conversions (13 February 2025): ESMA

What to have ready for 3 September

The work between now and the go-live is a technical implementation exercise against ESMA’s v2.0 interface. Map the v2.0 specification against your current weekly output, add the Report type field and two-report logic where options are traded, switch electricity and natural-gas quantities to the specified units of the underlying, and remove spot-emission-allowance records from the weekly extract. Keep the Article 83 threshold logic aligned to the current governing text and identify ESMA’s combined futures-and-options treatment as Technical Advice unless an adopted amendment is identified. Run a full file through validation before the first live v2.0 submission after 3 September 2026.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.