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 (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.
MiFID I transaction reporting only applied to financial instruments admitted for trading on a regulated market (and to OTC derivative contracts and other financial instruments linked to those instruments).
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.
UK & Europe Trade Reporting - EMIR
EMIR requires all market participants to report details of all derivative contracts (interest rate swaps, FX, credit, equity and commodity) to Trade Repositories. Read More
Australia Trade Reporting - ASIC
Find out more about the requirements for Australian OTC derivatives reporting under the ASIC regime. Read More
Singapore Trade Reporting - MAS
Find out more about the requirements for Singaporean OTC derivatives reporting under the MAS regime. Read More
Hong Kong Trade Reporting - HKMA
The Hong Kong Monetary Authority (HKMA) requires specified OTC derivative transactions to be reported to HKTR. HKMA reporting obligations in relation to retail OTC Derivatives will come into effect from 1 July 2017. Read More
UK & Europe Trade Reporting - MiFID II
MiFID II extends the derivative transaction reporting obligations of MiFID to a larger group of businesses. Read More