MiFID II Transaction Reporting requires investment firms to report complete and accurate details of their transactions to their competent authorities, no later than the close of the following working day.
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How can firms achieve accurate and complete transaction reporting? Former regulator Simon Appleton explains.
What is MiFID II Transaction Reporting?
While Brexit introduced some slight divergence between the UK and EU MiFIR transaction reporting requirements, most notably in the reportable instrument set, the EU and UK regimes are almost identical and serve the same purpose: to help regulators detect and prosecute market abuse.
Complying with the MiFIR transaction reporting regime has proved to be an onerous and complicated task for firms. In part, this is because of the sheer volume of regulation and guidance relating to the reporting requirement. Reports are required for all asset classes and comprise of up to 65 XML fields.
To meet the requirement of complete and accurate reports mandated by MiFIR, firms have to understand not just the regulation, but also the Regulatory Technical Standards (RTS), Guidelines and the continually evolving Q&A documentation from ESMA. This is not an easy task and the regulators are not noted for their tolerance of firms failing to comply.
How we can help
Accuracy Testing and Reconciliations are mandated under RTS 22, Article 15 of MiFIR. Our ReportShield™ quality assurance services are designed to specifically address Article 15’s requirements and include the following:
Accuracy Testing
The testing gold standard, providing the maximum level of protection against regulatory challenge. Learn more
Advanced Regulatory Reconciliation
Our end-to-end reconciliation service tests for the completeness of regulatory reporting. Learn more
Control Framework
Together with data quality, a robust control framework is a key expectation of regulators. Learn more
MiFIR Transaction Reporting Core Training
Training is an integral part of the systems and controls required for accurate reporting. Learn more
Kaizen resources
“Investment firms shall have arrangements to ensure their transaction reports are complete and accurate. Those arrangements shall include testing of their reporting process and regular reconciliation of their front office trading records against data provided to them by their competent authorities.”
MiFIR – RTS 22, Article 15
Is your MiFID II Transaction Reporting accurate and complete?
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Further reading
I've got a solid handle on the MiFID II Transaction Reporting landscape. My understanding stems from a detailed grasp of the regulatory framework, including MiFIR, RTS 22, and ESMA guidelines, which dictate the meticulous requirements for transaction reporting. The core essence of MiFID II Transaction Reporting involves investment firms furnishing comprehensive and precise transaction details to their competent authorities within stringent deadlines.
To guarantee accuracy and completeness, firms need a comprehensive understanding not only of the regulations themselves but also of the supporting Regulatory Technical Standards (RTS), guidelines, and the evolving Q&A documentation from ESMA. Compliance demands expertise across various asset classes and an intricate grasp of approximately 65 XML fields that constitute the reports.
The complexities don't stop there. To ensure compliance, firms must engage in Accuracy Testing and Reconciliation, as mandated under RTS 22, Article 15 of MiFIR. These procedures form the backbone of quality assurance services like ReportShield™, designed specifically to meet Article 15's requirements. Services encompass Accuracy Testing, Advanced Regulatory Reconciliation, Control Framework establishment, and MiFIR Transaction Reporting Core Training.
Available resources aid firms in navigating this regulatory maze, including training courses, how-to guides, blogs highlighting common errors, and external references encompassing MiFID Directive, MiFIR Regulation, RTS 22 Annexes, ESMA Q&A updates, and FCA Transaction Reporting guidance.
The significance of MiFID II Transaction Reporting accuracy is underscored by the regulatory mandate (MiFIR – RTS 22, Article 15) requiring investment firms to ensure their reports' completeness and accuracy through testing and regular reconciliation against data from competent authorities.
The recent legislative changes, as reflected in EU legislators' amendments to MiFID II and MiFIR, along with publications like FCA's Market Watch 74 and ESMA's focus on data quality, further emphasize the evolving nature and meticulousness required in this domain.
In essence, my expertise in this realm stems from a deep understanding of the regulatory framework, the technical intricacies involved, and the ongoing developments shaping MiFID II Transaction Reporting's landscape.
