MISP × FiDA: Why the Irish Presidency's Two Biggest Financial Files Intersect

Introduction

When the Irish Presidency took over the EU Council chair on July 1, 2026, it inherited two financial services files that will shape how EU institutions handle financial data for the next decade.

The first is MISP, the Market Integration and Supervision Package, the Presidency's headline financial services priority, targeting political agreement at October ECOFIN 2026.

The second is FiDA, the Financial Data Access Regulation, currently in trilogue, with the WP FICO September cluster the window in which negotiations are expected to restart, and political agreement still targeted for 2026.

These are not two separate compliance problems. For financial institutions in MISP scope, they are two layers of the same data infrastructure challenge, and planning for one without the other creates a rebuild risk.

What Is MISP?

The Market Integration and Supervision Package is the Irish Presidency's primary financial market reform initiative. It targets deeper integration of EU capital markets, stronger supervisory convergence between national competent authorities and ESMA, and better data transparency across financial instruments and market participants.

MISP affects investment firms, trading venues, financial data reporting entities, and the infrastructure providers that serve them. The target for political agreement is October 2026 ECOFIN, which makes it one of the clearest legislative deliverables of the Irish Presidency period.

What Is FiDA?

The Financial Data Access Regulation establishes a framework for open finance data sharing in the EU. Under FiDA:

• Data Holders (banks, insurers, investment firms, pension funds) must expose customer financial data via standardised, certified APIs.

• FISPs (Financial Information Service Providers) access this data through authorised channels.

• FDSS (Financial Data Sharing Schemes) operate the common layer between them, providing the technical standards, governance, and compliance architecture.

FiDA's scope explicitly includes investment data, the same data generated by entities in MISP scope.

Where MISP and FiDA Intersect

1. The same institutions carry both sets of obligations

An EU investment firm subject to MISP's supervisory and transparency requirements is also a Data Holder under FiDA. It must simultaneously:

• Meet MISP's data reporting and transparency standards for market supervision.

• Build or procure FDSS-ready APIs to expose customer investment data under FiDA.

Both create API and data management infrastructure obligations. Building these one after the other, MISP first and FiDA second, is the more expensive path. The institutions building shared foundational data infrastructure now will avoid the rebuild cycle.

2. Data governance convergence

MISP creates stronger data governance requirements for investment data: transparency, reporting accuracy, supervisory access. FiDA creates a parallel data-sharing mandate, where customer investment data must be accessible to authorised FISPs via certified channels.

These requirements draw on overlapping data categories. An investment firm managing its MISP data governance for regulatory reporting is managing the same underlying data it will need to share under FiDA. The data architecture that satisfies MISP's reporting requirements is the foundation on which FiDA compliance is built.

3. Supervisory timing creates a double compliance deadline

The Irish Presidency is targeting MISP political agreement in October 2026. FiDA negotiations are expected to restart in the WP FICO September cluster. If both files advance in the September to October 2026 window, financial institutions face converging compliance preparation timelines.

Institutions that have scoped their data infrastructure for MISP without also scoping for FiDA will be starting FiDA infrastructure design from scratch at a point when implementation windows are already compressing.

4. ESMA as the common thread

MISP's supervisory convergence provisions run through ESMA. FiDA's technical standard development, covering FDSS specifications and API standards, is mandated to ESMA and EBA jointly. ESMA is producing the technical standards for both frameworks in overlapping timeframes.

This means the regulatory technical standards that financial institutions need to implement for MISP compliance are being produced by the same institution producing FiDA's FDSS technical standards. Monitoring one file requires monitoring the other.

What This Means for Infrastructure Teams

Scope now, not later. Financial institutions in MISP scope, including investment firms and financial data reporting entities, should identify their FiDA Data Holder obligations in the same scoping exercise. A MISP compliance review that does not include FiDA creates a gap that will become apparent at the worst possible time: when FiDA's implementation window opens.

Don't build twice. MISP's data reporting infrastructure and FiDA's data-sharing infrastructure share common layers: API connectivity, data governance, customer consent management, auditability. Building these separately is the high-cost path. Building a shared foundational layer and extending it for each regulatory requirement is the correct approach.

Watch the October ECOFIN for both files. MISP political agreement and FiDA restart trajectory will both be clearer by late October 2026. Infrastructure teams should have their dual-track assessment complete before that window, not after.

InfraFIDA's Position at the MISP × FiDA Intersection

InfraFIDA builds FIDA-compliant data-sharing infrastructure for both Data Holders and Data Users. Our infrastructure layer is designed to be compatible with the technical standards ESMA and EBA are producing for FDSS, the same ESMA whose supervisory mandate is being expanded under MISP.

Financial institutions planning MISP compliance have a natural starting point for their FiDA infrastructure review. The data architecture decisions that satisfy MISP's requirements are the foundation on which FiDA compliance is built.

InfraFIDA provides FIDA-compliant infrastructure for Data Holders and Data Users across the EU. Contact: info@infrafida.com