Understanding National IDs in MiFIR Transaction Reporting


Natural Person Identifiers in MiFIR Transaction Reporting

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. The LEI requirements have received a lot of industry attention because the corporate client LEI is not just an identifier, but a pre-requisite to providing investment services to clients (though this is subject to temporary relief).

Many of the fields in MiFIR transaction reports require reporting of natural person information including identifiers, names and dates of birth.  The identifiers are a combination of the nationality of the client and an identifier used by the country in question.  Which identifier is used will depend on the priority given by the rules accompanying MiFIR

Fields which Require Population of a Natural Person or Corporate Identifier

The fields requiring inputs of natural person identifiers as provided in RTS 22 are summarised below.

Field numberField nameInput (if subject is natural person)
Buyer fields
7.Buyer identification codeNatural person identifier
8.Country of the branch for the buyerCountry code
If buyer is a client and a natural person:
9.Buyer – First Name(s)First name(s)
10.Buyer – Surname(s)Surname(s)
11.Buyer – Date of BirthDate of birth
If buyer is a client and acting under a power of representation:
12.Buyer decision-maker codeNatural person identifier
If buyer is a client, acting under a power of representation and natural person
13.Buyer decision maker – First Name(s)First name
14.Buyer decision maker – Surname(s)Surname
15.Buyer decision maker – Date of BirthDate of birth
Seller fields
16.Seller identification codeNatural person identifier
17. - 24. [Mirror buyer fields 8. – 15.][Mirror buyer fields 8. – 15.]
Investment decision and execution
57.Investment decision within firm*Natural person identifier
59.Execution within firm*Natural person identifier

Note: There are some exceptions e.g. where the identity of a party is not disclosed.

Rules for Use of Natural Person Identifiers

RTS 22 provides in Article 6(1) that a natural person should be identified by the two-letter country identifier provided by ISO 3166-1 as the ‘alpha-2’ code and the identifier provided in Annex II of the RTS. Annex II lists various identifiers for each country code (up to three in order of priority), as depicted in the example below.

Annex II
ISO 3166 - 1 alpha 2Country Name1st Priority Identifier2dn Priority Identifier3rd Priority Identifier
BEBelgiumBelgian National NumberCONCAT
BGBulgariaBulgarian Personal NumberCONCAT
CYCyprusNational Passport NumberCONCAT

The identifier will typically be a passport number or a unique code specific to a country e.g. UK National Insurance Number.  For citizens of some countries, or where the primary mode of identification is unavailable, a CONCAT code will be required to identify the natural person which is a concatenation of the name and date of birth (see right hand column of the table below).

The rules around use of natural person identifiers are provided in the other parts of Article 6 are as follows:

Basic RuleTwo-digit 'alpha 2' Code plus Annex II IdentifierCONCAT
Priority of IdentifierThe highest priority identifier that a person has as provided in Annex II should be used. It is not relevant that an investment firm may not know the highest priority identifier.Concatenation (combination) of:

1. Date of birth (YYYYMMDD)

2. First five characters of first name

3. First five characters of surname

Note: for first names and surnames, prefixes and punctuation are excluded and if the name is less than five characters then use # to fill remaining spaces.

Nationality(ies) of the Natural Person
More than one European Economic Area (EEA) countryUse two-letter alpha-2 code which is first when arranged alphabetically and use corresponding identifier from Annex II
Non-EEA'All other countries' field in Annex II to be used - this is the National Passport Number and CONCAT (see column to the right)
EEA and non-EEAThe two-letter alpha-2 code and the identifier provided in Annex II (i.e. same as EEA only nationality)

Firms need to make sure that this data is not only in their possession but that it is stored in such a way as to make it readily accessible for the purpose of generating and submitting daily transaction reports.

To discuss national identifiers please contact us.

Share this Post:

Stay in the Know

Recent Articles:

Do crypto-asset service providers have MiFIR reporting obligations?

Do crypto-asset service providers have MiFIR reporting obligations?

To address the Money Laundering/Terrorism Financing (ML/TF) risks emanating from crypto-assets, the Cyprus Securities and Exchange Commission (CySEC) published a policy statement (PS) on 13 September 2021 to outline its approach to the registration and operations of Crypto Asset Services Providers (CASPs).