FMIR (Z.09) – Scope of ECMS as an FMI and clarification on “Operator of the FMI” (0080)

CaixaBank began operating with ECMS (Eurosystem Collateral Management System) in 2025. We wanted to understand whether it is actually considered an FMI and whether it should be included in the Z.09 reporting, since, being an ECB collateral management platform, it does not fit into any of the existing categories such as payment systems, CSDs/SSSs, CCPs or trade repositories. We have also reviewed the list included in the annex to the EBA reporting instructions, and it does not appear there. In Z.09.01. there is a new field called “Operator of the FMI (0080)”, and we have many doubts about what is expected to be reported. The instructions only state the following: “Name of the operator of the FMI”. Is it expected that the legal entity should be completed? For example, for the FMI Euroclear, should it be reported as → Euroclear Bank SA/NV; and similarly for TARGET2 → ECB – Eurosystem? Or, in the case of direct connectivity with the FMI (for example, TARGET2), should Banco de España be indicated as the operator? In that case, how should this be handled for custodians and other FMIs?

The questions arise in the context of the first year of application of the revised FMIR templates under Regulation (EU) 2025/2303.  ECMS started operating in 2025 and represents a new Eurosystem infrastructure not previously considered in FMIR reporting. In parallel, template Z.09.01 introduces a new data field (“Operator of the FMI”, column 0080) for which limited guidance is available.  Clarification is needed to ensure consistent and harmonised reporting across institutions.