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MiFID II/MiFIR Reporting

Markets in Financial Instruments Directive and Markets in Financial Instruments Regulation

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MiFIR (the Markets in Financial Instruments Regulation) and MiFID II (the second Markets in Financial Instruments Directive came into effect on 3 January 2018. Due to Brexit, the EU regulations have been onshored under the European Union (Withdrawal) Act 2018. On this page, MiFIR refers to both EU and UK MiFIR unless otherwise specified.

MiFIR and MiFID II 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. 

The scope of the MiFIR reporting regime includes:

  1. financial instruments admitted to trading or traded on an EEA trading venue or for which a request for admission to trading has been made;
  2. 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); and
  3. financial instruments where the underlying instrument is an index or a basket composed of financial instruments traded on a trading venue.

What is the reporting obligation?

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.

It is important to note that where an EU investment firm has executed its transactions via a UK branch or vice versa, the entity will have a dual reporting obligation. The FCA has made it clear post-Brexit that the branch will no longer be able to discharge the reporting obligations by transmitting orders to the other entities.

Who is required to report?

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 to report and to whom?

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; and
  • date & time of trade – must be provided for each trade.

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

Wondering where to report your transactions post-Brexit?  To an EU ARM or a UK ARM?  Click here.

What are the MiFIR trade publication requirements?

The regulation requires 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.

For more information on trade publication requirements, please head to:

What is a trading venue?

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

  • Regulated Market
  • Multilateral Trading Facility
  • Organised Trading Facility

Do you know the difference? View our comparison of the three trading venues in this article.

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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. Read more.

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, so that you can stay compliant with the trade/transaction reporting requirements. Read more.

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. Read more.

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. Read more.

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. Read more.

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. Read more.

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 considers three of these fields in turn. Read more.

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.

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. Read more.