CFI and ISIN Codes Under EMIR and MiFIR
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Reporting of a wide range of identification and classification codes is one of the major aspects of transaction reporting. The range of product identifier codes required by the reporting regimes of EMIR and MiFIR include:
- International Securities Identification Number (ISIN);
- Classification of Financial Instruments (CFI); and
- Alternative Instrument Identifier (Aii).
Use the decision tree below to determine which product identifiers you should be reporting.
1. What is a UPI?
A Unique Product Identifier (UPI) is made up of specific values on reference data components. It sits in the UPI Reference Data Library on ANNA-DSB and its use is identical across the EMIR (UK and EU), ASIC, MAS, Canada and CFTC trade reporting regimes. Conceptually, UPIs sit between CFI codes and ISINs (both discussed below) and also work together with Unique Transaction Identifiers (UTIs) and Critical Data Elements. For more information on the UPI framework and UTIs, please see our articles here and here.
2. What is an ISIN?
An ISIN is a unique code that is used to identify a financial instrument (security). Its structure is defined in the standards document International Securities Identification Number (ISO 6166). ISO 6166 is an international standard promulgated by the International Standards Organisation and has worldwide application.
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3. What is the CFI and how is it used to classify products?
The CFI is a 6-character code used to classify a financial instrument, as defined in ISO 10962.
| First character | Highest level of category to which the instrument belongs – e.g. Equities (E), Debt (D), Options (O), Futures (F), Forwards (J) etc. |
| Second character | Specific groups within each category – e.g. Financial Futures (FF) Commodity Futures (FC). |
| Third to Sixth characters | Refer to each group’s main features or attributes. |
| N.B. The letter X always means Not Applicable/Undefined |
By way of example, if we look at the similarities and differences between a CFD and spread-bet on an equity instrument.
The CFI code for a CFD on an equity is JESXCC:
| J | Forward |
| E | Equity |
| S | Single stock |
| X | Not applicable/undefined |
| C | Contract for difference |
| C | Cash settled |
The CFI code for a spread-bet on an equity is JESXSC:
| J | Forward |
| E | Equity |
| S | Single stock |
| X | Not applicable/undefined |
| S | Spread-bet |
| C | Cash settled |
Both instruments are classed as Forwards (J) and have the same underlying instrument so they share the same group and first attribute. They are both cash settled so the only difference is the fifth character which relates to the differing ‘return or payout trigger’ (the third attribute for forwards).
4. EMIR Reporting
Under the revised EMIR RTS, the CFI, UPI and ISIN will need to be submitted with transaction reports.
a) Product classification – reporting of CFI and UPI
‘Product Classification’ is a mandatory field in EMIR transaction reports under the revised EMIR RTS. The UPI and the CFI code are the only options for classifying an instrument in a transaction report.
b) Product identification – reporting of ISIN
The ISIN is the only method available for identifying instruments in EMIR transaction reports.
5. MiFID II/MiFIR Reporting
The ISIN is required to be reported for MiFIR reporting. Where an ISIN is not available, you will be required to report a CFI and possibly other information.
a) Reporting of ISIN
Where an ISIN for an instrument is available, it must be used to identify the instrument in a MiFID II/MiFIR transaction report. In this instance, a CFI and UPI are not required.
Use of the ISIN is to be expanded to identify OTC derivatives traded on venue or by a systematic internaliser (SI). This aligns with the requirement of MiFIR RTS 23 relating to Reference Data:
“Prior to the commencement of trading in a financial instrument in a trading venue or systematic internaliser, the trading venue or systematic internaliser concerned shall obtain the ISO 6166 International Securities Identifying Number (ISIN) code for the financial instrument”. Commission Delegated Regulation (EU) 2017/585 of 14 July 2016.
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