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Self-Reporting vs Delegated Reporting under EMIR, MiFIR and SFTR

Data Enrichment

Compliance Support

Reduce Costs

With so many compliance obligations to keep on top of, have you considered delegating your reporting obligations?

The resources (financial, people, technology) required for ongoing compliance need to continually improve processes at an investment firm to stay abreast of changing regulatory requirements.

TRAction understands the struggles that many firms are facing. We have compared the steps required to complete an onboarding process with us as opposed to onboarding with an Approved Reporting Mechanism (ARM)/Trade Repository (TR) directly.

Self-reportingReporting through TRAction
Complete onboarding with an ARM/TRComplete onboarding with TRAction
Obtain file specifications from the ARM/TRProvide a file sample or access to data (for automated data transfer)
Review field requirementsWork with the onboarding team to ensure that the data is in the correct format
Test connections to ensure you can submit filesFinalise submission procedures
Populate files and upload to the ARM/TR in the User Acceptance Testing (UAT) environmentReview the output file and contact TRAction to make any corrections
Review the output file and correct if necessary

Additionally, we have summarised the top 3 ways in which delegated reporting can benefit you and maximise the effectiveness of your team.

Self-reportingReporting through TRAction
Limited Internal Resources


Meeting the reporting requirements may required re-training existing staff or hiring additional staff. The former can divert human resources from existing projects and the latter adds to employment expenses.

Free up Internal Resources


Free up internal resources and allow your team to focus on your firm's core offering.
Burden on Infrastructure


Firms need to spend time and resources to develop ways of generating transaction reports in the correct formats. This in addition to the procurement and storage of all the required data.

Reduce Infrastructure Cost


Limit the infrastructure expenditure you incur. We have IT specialists who can work with your IT team to adjust your systems to be reporting-ready, again without additional charge.
Trade Repository Fees


Firms can directly engage with an ARM for MiFIR or TR for EMIR and SFTR. Charges are generally a fixed monthly or annual account fee plus a per-transaction charge.

Cost Efficiency


Reduce the need to obtain and pay for external advice. At TRAction, we provide regular regulatory guidance in our fees to improve your reporting obligations without engaging expensive external consultants. Best of all, we don't add these charges to our base reporting offering.

When you onboard with us, we offer:

  1. Easy transfer of data – we can either set up direct connection with your platform to extract data or you can provide us with your data files for a seamless transition
  2. High level of expertise – trade reporting is TRAction’s core business offering which means we invest all of our time and energy into streamlining your reporting processes as well as providing guidance on the regulation
  3. Friendly and dedicated team – we have an enthusiastic team with customer-focused mindset which helps us deliver more effective solutions. With our talented staff, we can also provide services in multiple languages if required.

Interested to know more about how TRAction can make your business operations easier? Contact us for a free demo and we can talk you through how to simplify your trade and transaction reporting processes.

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Further Information

Understanding your reporting obligations and determining whether a third party reporting solution will save you costs and internal resources are important steps towards compliance with your trade and transaction reporting requirements. Choosing a strategic approach to compliance will give you a competitive advantage and ensure you avoid penalties for non-compliance. To make things easy, we’ve created the User Friendly Guide to Transaction Reporting in Europe.

TRAction has outlined the key differences between MiFIR and EMIR. Our team has also pointed out some of the issues that investment firms need to be aware of under EMIR and MiFIR. Read how you can stay compliant with the trade/transaction reporting requirements.

As a delegated reporting service provider, TRAction is asked a lot of questions regarding EMIR, MiFIR and SFTR reporting. That’s why our team has put together some of our most frequently asked questions, so that you can learn how to seamlessly report transactions under multiple regimes. 

We’ve identified the 3 most common errors in the transaction data we receive from our clients:

  1. Missing customer details
  2. Duplicate transactions
  3. Incorrectly formatted dates


Read more for our guidelines on how to prevent and rectify these errors.

While EMIR and MiFIR trade and transaction reporting rules allow reporting entities to delegate their reporting obligations to a third party, they remain ultimately responsible for ensuring the details of their transactions are reported correctly and accurately under Art 9(1) of EMIR & Art 26(7) of MiFIR. See the steps TRAction suggests to ensure the completeness, accuracy and currency of the trade/transaction information reported.

As part of MiFIR/UK MiFIR, Investment Firms should have arrangements in place to regularly reconcile their front office transactions against data samples provided by their National Competent Authority (NCA). 

If your NCA does not have samples to provide, as an Investment Firm you should look to reconcile against files that your ARM or Trading Venue has submitted on your behalf, for example, the handback files from your ARM. See what you need to do as a MiFID Investment Firm.

We all know that meeting all the requisite trade/transaction reporting obligations for EMIR, MiFID II/MiFIR and SFTR can pose a considerable cost to an investment firm. While the regulatory burden is not going to disappear, it can be minimised by outsourcing and choosing the most cost-effective and efficient option for you.

Determining how to make the reports and how to populate these fields is often not a straightforward exercise due to differences in licensing and reporting definitions, as well as certain field criteria being conditional on the input of other fields. TRAction’s co-CEO, Quinn Perrott, considers three of these fields in turn.

Articles 6, 10, 20 and 21 of MiFIR require European Investment Firms (IFs) to make public, through an Approved Publication Arrangement (APA), post-trade transparency information in relation to financial instruments which are traded on a Trading Venue or traded over-the-counter (OTC)/off exchange.

The obligation only requires one counterparty to report the trade data. Read more to ensure your understand your trade publication requirements.

Natural person identifiers are an important part of transaction reporting and contain some complexity in their application due to the variety of identifiers available. 

It’s widely-known that corporate counterparties need to be identified by their legal entity identifier (LEI) in MiFIR transaction reports. This is simple and straight-forward.

Where the counterparties are natural person, the reporting of natural person information including identifiers, names and dates of birth will be required. The type of identifier to be used will depend on the priority given in the Annex II of RTS 22. See which national personal identifiers you should use.