MiFID II / MiFIR

Transaction Reporting Obligations

As transaction reporting obligations are contained in the MiFIR regulation, there cannot be differing implementation between European nations.  MiFIR imposes transaction reporting obligations in respect of specified transactions in financial instruments where the underlying instrument is traded on a European Economic Area (EEA) trading venue.

Which instruments are caught by the new regulations?

The scope of the MiFIR reporting regime includes:

• financial instruments admitted to trading or traded on an EEA trading venue or for which a request for admission to trading has been made;
• financial instruments where the underlying financial instrument is traded on a trading venue (ToTV) (guidelines state ‘underlying’ means immediate underlying instrument rather than ‘ultimate’ underlying instrument).
• financial instruments where the underlying instrument is an index or a basket composed of financial instruments traded on a trading venue.

What is a trading venue?

Under MiFID II/MiFIR, there are 3 categories of trading venue:

1. Regulated Market
2. Multilateral Trading Facility
3. Organised Trading Facility

Do you know the difference? Find it out in our explanatory infographic designed for you!

Which entities need to report?

MiFIR transaction reporting obligations extend to:

• investment firms;
• investment managers providing advice and portfolio management to individuals;
• credit institutions;
• market operators;
• all financial counterparties under EMIR;
• central counterparties and persons with proprietary rights to benchmarks; and
• third-country firms providing investment services or activities within the EEA.

What information needs to be reported?

There are 65 reporting fields under MiFIR, including:

• Identification of the relevant parties – the legal entity, natural person or algorithm which submitted the order, made the investment decision or executed the order.
• Identifying information – a Legal Entity Identifier (LEI) for legal entities and personal identification information for natural persons.
• Product classification and identification – CFIs and ISINs for financial products.

Where should reports be made?

Firms can report directly to their National Competent Authority (NCA), or indirectly through an Approved Reporting Mechanism (ARM) or a third-party assisted reporting solution.

If you would like assistance in understanding MiFIR transaction reporting obligations and how we can help you simplify your reporting, please contact us on +44 20 8050 1317 in the UK or +357 25 123 309 in Cyprus.

Delegated Reporting – How can we help you?

TRAction provides clients with delegated reporting solutions in accordance with the reporting requirements outlined above.

Our clients can also conduct regular check of our service quality. Visit our Regular Quality Checks page to find out how you can be assured that we are doing a great job for you.

Transitioning to new EMIR & MiFIR Reporting

In the midst of an unprecedented global crisis, CME Group has announced its closure of most of its regulatory reporting services including NEX Regulatory Reporting and the CME European Trade Repository by 30 November 2020. We understand the stress and inconvenience this may bring to CME’s existing clients in terms of switching to another TR, ARM or reporting delegate.

If you are currently a client of the CME’s regulatory reporting entities, TRAction is here to help you and ensure a smooth transition of reporting services on or before 30 November 2020. Click here to find out more.