MiFID reporting after the Brexit transition period

Read this page if your firm is migrating to FCA FIRDS or FCA FITRS after 31 December 2020.

Quarterly determination of liquid bonds

For the purposes of the pre and post-trade transparency rules for bonds that are traded on UK trading venues, we are required to publish a list of those bonds we have determined to have a liquid market. For the purposes of the determination to apply from 16 February to 15 May 2021, we can confirm that, in line with paragraph 34 of the Supervisory Statement we published last year, we have not determined that any bonds that are traded on UK trading venues have a liquid market. This determination applies to bonds that started trading on UK trading venues on or before 30 November 2020.

The next quarterly determination of which bonds that are traded on UK trading venues have a liquid market will be published by 10 May 2021 to apply from 16 May 2021.

Go-live of the onshored MiFID regime

When the transition period ends on 31 December 2020, the European Securities & Markets authority (ESMA) will switch off the FCA’s access to its MIFID systems.

2 key systems are ESMA FIRDS, which provides reference data for all MiFID instruments that are Traded on a Trading Venue (TOTV) in the EU, and ESMA FITRS, which publishes reference data, liquidity, waiver thresholds and quantitative data to help firms assess their trade reporting and tick size obligations.

To prepare for this, and provide operational continuity to UK firms, we have built equivalent FCA systems in the UK, called FCA FIRDS and FCA FITRS. Both of these systems are available to firms for connectivity and output in testing (the parallel run).

How the transition to the new systems will work

On 16 December, we will close these parallel run systems, rebuild our data and launch them with refreshed data in our production environments.

This page summarises the timeline of each system’s availability prior to cutover, throughout the cutover weekend, and the FCA FIRDS and FCA FITRS publication schedule up to the end of the first trading day after cutover (4 January 2021). It also outlines the instrument coverage in FCA FIRDS and FCA FITRS for the first weeks following the cutover.

What you need to do

Use the table below to understand the dates and times for the system cutover and make sure you take any appropriate action before 16 December.

Cutover system availability timeline

16 December 2020 FCA FIRDS and FITRS publication websites and API will close and will not reopen until Saturday 2 January. All MDP production environments will remain open, except where indicated below.
31 December 2020 8.30pm GMT: ESMA FIRDS maintenance window starts. After this point, feedback files for FIRDS will be generated by FCA FIRDS rather than ESMA FIRDS.
11pm GMT: FCA and ESMA will cut infrastructure connections. No files submitted after this time will be passed through to ESMA. MDP will close for ingestion for a few hours while our systems are repointed to FCA FIRDS and FCA FITRS. Firms that need to submit T+1 by Thursday should aim to get reports before 11pm GMT to avoid this MDP outage. As 1 January is a public holiday, firms not needing to submit T+1 by Thursday will be able to submit at the latest on Monday 4 January.
1 January 2021 We expect the MDP to re-open in the early hours of 1 January. Firms may wish to plan to restart file submissions from 6am onwards. Feedback files will be available from midday, after the FCA’s system completes loading the full history of instruments from ESMA. If there are delays we aim to communicate these on the MDP entity portal. 
2 January 2021 Around 2pm GMT, we aim to publish full and delta files for both FITRS and FIRDS. These files will contain all relevant instruments from the ESMA history at 31 December 2020. At this point the API will be running on the FCA publisher.
3 January 2021 Normal, non-trading day. This is a contingency day in case we encounter implementation problems.
4 January 2021 Normal trading day. We aim to produce a FIRDS delta file by 8am GMT on Monday morning. We will also make a CRA deployment, which may slightly delay the delta file for FCA FIRDS. The API will remain available. An FCA FITRS delta file will be produced after business hours. Both these deltas will reference changes from the publication of the deltas on 2 January.

Instrument coverage in FCA FIRDS

From 2 January, FCA FIRDS will contain all active ESMA instruments up to 31 December 2020, including:

  • all instruments traded on a UK trading venue
  • all instruments traded on an EU-27 trading venue, but not traded in the UK

Any instruments traded on a UK trading venue (regardless of whether they were also traded in the EU-27) will be 'GB' for the purposes of the Relevant Competent Authority (RCA) field and will have a UK Most Relevant Market (MRM). These changes to MRM and RCA fields will mean the delta files on 2 January 2021 will be very large (around 4 million records).

Any instruments that were only traded on-venue in the EU-27 prior to 1 January 2021 (ie were on ESMA FIRDS but were not traded on a venue in the UK) will be published on FCA FIRDS but will retain their pre-1 January 2021 RCA (ie an EU-27 RCA) and their pre-1 January 2021 MRM. These instruments will therefore be easily distinguishable from instruments trading on venues in the UK.

From 1 January (publishing starting on 2 January) we will also be publishing on FCA FIRDS any instrument newly admitted to trading in the UK. A newly-admitted instrument in the UK will replace any ESMA record (on FCA FIRDS) for the same ISIN (ie there should be no duplicate instruments in FCA FIRDS).

Firms wishing to build a complete history of all the instruments in FCA FIRDS from 2 January can do this by clearing down their pre-1 January 2021 data, replacing it with a full set of FCA data (FCA FIRDS FULINS and INVINS) published on 2 January. Firms that have been regularly uploading data from ESMA FIRDS in their production environments can also take the FCA FIRDS delta files provided on 2 January. These 2 January delta files are expected to contain around 4 million records.

Instrument coverage in FCA FITRS

FCA FITRS will publish all active ESMA FITRS instruments up to 31 December 2020, which were trading on a UK trading venue (ie we will exclude instruments that were only traded in the EU-27). The scope of FCA FITRS is therefore different from FCA FIRDS. All classes and sub-classes of instruments available on ESMA FITRS will be published on FCA FITRS.

From 1 January, we will be making (publishing from 2 January) transparency estimates as they fall due. In the case of equities, we will also make and publish (from 2 January) the first 4-week (FFWK) calculations as they fall due. Any FFWK calculations that fall due after 31 December 2020 will be made using UK data only.

For derivatives admitted to trading from 1 January 2021 onwards, we will only publish estimates for the following sub-classes: equity, interest rate, commodity, FX and securitisation.

Firms wishing to build an accurate history of all the instruments in FCA FITRS will need to clear down any pre-1 January 2021 data they have uploaded from ESMA FITRS and reload the full FCA FITRS files and deltas published by the FCA on 2 January. This is because the FCA will remove any instruments from our ESMA extract (published on 2 January) that are only TOTV in the EU-27. Firms cannot simply take the FCA delta file for FITRS on 2 January and apply it to pre-1 January 2021 data.

Page updates

08/02/2021: Information added Quarterly determination of liquid bonds