MiFIR EU & UK Regulatory Reporting

The deltaconX regulatory platform enables compliance with articles 20 & 21 as well as 26, and of the Markets in Financial Instruments Regulation (MiFIR, EU & UK) in a way that helps streamline day-to-day MiFIR reporting.

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.

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MiFIR EU & UK - Art. 26 Transaction Reporting (ARM)

The transaction reporting obligation under MiFIR is defined in Article 26 and requires investment firms and trading venues to report all changes to their or their clients’ positions in certain financial instruments by the end of the following business day (T+1). Either directly to their respective National Competent Authority (NCA) or to an Approved Reporting Mechanism (ARM)2

What is the reporting obligation?

Financial instruments in scope of the regulation are:

Instruments that have been admitted or requested admission to a trading venue
Instruments of which the underlying assets have been admitted or requested admission to a trading venue
Instruments based on Baskets and Indices and whose components have been admitted or requested admission on a trading venue
Reports can be sent directly to the relevant National Competent Authority (NCA) or via an Approved Reporting Mechanism (ARM).
Since the United Kingdom has left the European Union on the 1st of January 2021 the Financial Conduct Authority (FCA) has implemented onshore versions of the European regulations.

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.

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)
Financial instruments where the underlying instrument is an index or a basket composed of financial instruments traded on a trading venue.

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
Third-country firms providing investment services or activities within the EEA

When do reports have to be made?

All trades must be reported in T+1.

What is a trading venue?

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

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MiFIR EU & UK - Art. 20/21 Trade Reporting (APA)

Article 20 and 21 MiFIR defines the post-trade publication requirements for investment firms trading equity, equity-like and non-equity instruments on trading venues.

When do reports have to be made?

The following needs to be published in a post-trade report:

Who is required to publish?

Investment firms which, either on their own account or on behalf of clients, conclude transactions in shares, depositary receipts, ETFs, certificates and other similar financial instruments traded on a trading venue, shall make public the volume and price of those transactions and the time at which they were concluded. That information shall be made public through an APA.
Investment firms which, either on their own account or on behalf of clients, conclude transactions in bonds, structured finance products, emission allowances and derivatives traded on a trading venue shall make public the volume and price of those transactions and the time at which they were concluded. That information shall be made public through an APA.
Since the United Kingdom has left the European Union on the 1st of January 2021 the Financial Conduct Authority (FCA) has implemented onshore versions of the European regulations.

When does the post-trade information need to be published by?

Post-trade information shall be made available to the public as close to real time as is technically possible (Article 7 (4) of RTS 2) which means all trades must be reported within 5 minutes after the execution of the relevant transaction.

User-friendly compliance

A platform that helps you focus on what matters.

deltaconX provides highest flexibility by supporting multiple jurisdictions within a unified platform.

Integrated MiFIR Reporting

The deltaconX SaaS platform offers the capability to incorporate these MiFIR requirements into our unified and standardised workflow, which simplifies compliance by only highlighting the actual areas requiring attention.

Instead of needing expensive in-house expertise, or needing to sacrifice time and resources on ensuring compliance – deltaconX automations actually reduce manual efforts by up to 80% while providing an unprecedentedly clear TCO.

Evergreen Compliance is Futureproofed Compliance

As the regulatory reporting bodies start to move their focus away from data completeness towards data quality, remaining compliant will prove to become a bigger challenge over time.

Regulatory Reporting EMEA might be predictable, but as Brexit proved there are always surprises on the horizon – which makes the predictability of the deltaconX platform ideal when it comes to MiFIR reporting.