MiFID II / MiFIR

MiFID II (the second Markets in Financial Instruments Directive) and MiFIR (the Markets in Financial Instruments Regulation) came into effect on 3 January 2018.

MiFID II and MiFIR together govern all aspects of the financial markets, including trading and reporting of financial instruments.  Transaction reporting obligations are a large part of the regulatory regime and are contained in MiFIR. TRAction provides a full-service MiFIR solution that can simplify your transaction reporting requirements.  Contact us if you would like to discuss your transaction reporting obligations.

The scope of MiFID II is broader than MiFID I transaction reporting which 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).

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.

Delegated Reporting – How can we help you?

TRAction can provide you with delegated reporting solutions in accordance with the reporting requirements outlined above. We assist with understanding your MiFIR transaction reporting obligations and simplify your reporting process. If you want to find out more about our services, please contact us. Wondering about how much we charge? See our pricing schedules here.

Reporting Quality Checks

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.


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