ESMA ¦ Report on Suspicious Transaction and Order Reports (STORs) 2026

Market abuse reporting in the EU edges up as insider dealing stays in front

National competent authorities across the European Economic Area received 7,179 suspicious transaction and order reports (STORs) and related notifications in 2025, around 6% more than the 6,763 they received in 2024. ESMA’s annual overview of STOR reporting under Article 16 of the Market Abuse Regulation (MAR) describes a system that is stable rather than changing. Investment firms still file most reports, shares are still the instrument most often reported, and suspected insider dealing again outnumbers market manipulation, by 53% to 45%.

What a STOR is and who has to file one

Article 16 MAR requires market operators and investment firms that operate a trading venue, as well as any person professionally arranging or executing transactions, to maintain effective arrangements, systems and procedures to detect suspicious orders and transactions and to report them without delay. The duty covers orders as well as completed trades, including cancellations and modifications, and applies to transactions in any financial instrument whether they take place on or off a trading venue. Commission Delegated Regulation (EU) 2016/957 sets out the required arrangements and the notification template.

A report goes to the competent authority of the Member State where the reporting person is registered or has its head office, or where its branch is located. That authority must pass it on immediately to the authority of the trading venue concerned. A STOR is not an accusation. It is intelligence that supervisors use to open and support market abuse investigations, and its value depends on the information that only the firm handling the order can see.

Bastian Schwind-Wagner _Follow

"Behind each of these 7,179 notifications is a firm that saw something odd in an order book and decided to tell its supervisor. The overall numbers are steady, but the reporting is concentrated in a handful of countries and almost entirely on shares, which says as much about where surveillance is calibrated as about where abuse happens.

For compliance teams, a STOR is not only a market integrity duty. Insider dealing and market manipulation are predicate offences for money laundering, so the same facts can also call for a suspicious activity report to the FIU, and the two processes should be connected rather than run in parallel."

Volumes have settled on a higher level

Of the 7,179 notifications received in 2025, 6,324 were STORs within the meaning of Article 16 MAR and 855 were other notifications, such as substantial general complaints, market observations and reports from persons outside the scope of the article. STORs alone rose by 5%. All 30 EEA authorities took part in the data collection.

Over the longer term, the number of STORs has grown substantially since 2011. Since 2021 it has stayed within a range of roughly 5,800 to 6,500 a year, so 2025 sits near the upper end of that band.

Germany and France receive the most reports

Germany received 2,065 notifications in 2025, 29% of the total, followed by France with 1,077 (15%), Sweden (8%), Italy, Ireland and the Netherlands (6% each) and Hungary (5%). The pattern is the same for STORs alone, with Germany at 25% and France at 17%, although Germany’s share fell compared with 2024.

These figures show where reporting persons are based, because a STOR goes to the authority of the reporting firm’s home Member State. They do not show where abuse takes place, and a market with few reports is not necessarily a market with little abuse.

Investment firms remain the main source

Investment firms filed 76% of all notifications in 2025, in line with the 72% to 77% range seen every year since 2020. Other parties were the second-largest source at 12%, and persons professionally arranging or executing transactions that are not investment firms accounted for 8%. Regulated markets and MTFs or OTFs contributed less than in 2024, at 4% and 1% compared with 7% and 5% a year earlier.

The number of investment firms that submitted at least one STOR rose to 815, from 659 in 2024. France had by far the most reporting firms (267), followed by Germany (128), Austria (62), Italy (60), Sweden (49), Belgium (39), Denmark (27), the Netherlands (25) and Spain (24). Across the whole period since 2010, the number of reporting firms has fluctuated without a clear trend.

Shares dominate and insider dealing is back in front

Shares were the subject of 86% of notifications in 2025, followed by derivatives (6%), other instruments including structured products and exchange-traded products (4%), bonds (3%) and combinations of instruments (under 1%). Over the years, shares have accounted for between 67% and 93% of STORs.

The split between types of suspected abuse has moved over time. Until 2018, insider dealing made up between 51% and 69% of reports. From 2019 to 2022, market manipulation took the lead at around 52% a year. Insider dealing has been the largest category again since 2023, at 51% that year, 57% in 2024 and 53% in 2025, while market manipulation accounted for 45% in 2025. Reports covering both forms and reports on other violations made up about 1% each. That last category includes conduct outside the MAR offences, money laundering for example, that may be connected with market abuse.

Reports increasingly cross borders

Because a STOR often concerns a trading venue in another country, authorities forward many of them. In 2025, they sent 1,659 STORs to other EEA authorities only, up from 1,541 in 2024, and 376 to third-country authorities only, up from 327. In a further 313 cases, the same STOR went to both. Germany sent the most STORs to other EEA authorities (36%), followed by Ireland (22%), France (13%) and the Netherlands (10%). France (27%), Cyprus (20%) and Denmark (14%) sent the most to third-country authorities only, while Cyprus accounted for 41% of the STORs sent to both.

The total passed on to other authorities reached 2,348 in 2025, compared with 607 in 2017 and 703 in 2018, although part of the recent increase reflects a change in how STORs sent to both groups are counted. In the other direction, authorities received 1,628 STORs from other EEA authorities and 531 from third-country authorities, against 1,616 and 464 a year earlier. Germany received the largest share of STORs from other EEA authorities (34%), while France (29%) and Germany (24%) received the most from outside the EEA.

Fewer details, cleaner comparisons

For the 2025 data, ESMA simplified the reporting template it uses with national authorities. It no longer asks for a cross-classification of notifications by reporting party and by instrument or type of violation, so some of the more detailed breakdowns of earlier editions are not available this year. Historical series are also presented without UK data wherever it can be separated, which makes year-on-year comparisons more reliable. Where UK figures could not be separated from the aggregates, the series include them up to 2018.

What firms should take from the numbers

The figures describe the system as a whole, but each STOR starts with a firm’s own surveillance. The concentration on shares suggests that many firms calibrate their alerts mainly for equity markets. Firms that trade bonds, derivatives or structured products for themselves or for clients should check whether their surveillance covers those instruments with the same depth. The duty also covers orders that were never executed and trades outside trading venues, which a monitoring set-up based only on executed on-venue trades will miss.

The link to anti-money laundering work deserves attention too. Insider dealing and market manipulation generate proceeds and are predicate offences for money laundering. A STOR sent to the market supervisor does not replace a suspicious activity report to the financial intelligence unit where the facts also point to money laundering. In Luxembourg, the first goes to the CSSF and the second to the Cellule de Renseignement Financier (CRF). Firms are best served by a process that assesses each case under both regimes, documents the decision and keeps the tipping-off prohibitions of both in mind.

Dive deeper

• ESMA ¦ Report on suspicious transaction and order reports (STORs) 2026 ¦ Link