A transaction report is data submitted to us which contains information relating to a transaction. We use the reports to detect and investigate suspected market abuse. They may also be used for conduct supervision purposes and to support the work of other regulatory authorities such as the Bank of England.
Complete and accurate data is critical to transaction reporting. In order to be able to monitor for market abuse effectively, competent authorities need to receive complete and accurate information regarding the types of instruments, when and how they are traded and by whom. This is set in Article 26(1) of MiFIR which states that investment firms which execute transactions shall report “complete and accurate details” of such transactions.
Each transaction report includes, amongst other elements:
- information about the financial instrument traded
- the firm undertaking the trade
- the buyer and the seller
- the date/time of the trade
The Markets Reporting Team (MRT) is responsible for monitoring the quality of transaction reporting data. They are also responsible for specialist supervision of firms’ compliance with the transaction reporting provisions and for the formulation of transaction reporting policies and instrument reference data.
The European Securities and Markets Authority ESMA has developed guidelines on transaction reporting, order record keeping and clock synchronisation ('the Guidelines') and is a point of reference to help firms comply with their transaction reporting obligations.
Errors and omissions notifications
Who can submit transaction reports?
Under Article 26(7) of MiFIR transaction reports can only be submitted by:
- an investment firm submitting their own reports
- an Approved Reporting Mechanism (ARM) acting on behalf of an investment firm
- a trading venue through whose systems the transaction took place
All transaction reports are to be made only once to the home competent authority, regardless of whether a branch is involved.
- ARMs and investment firms submit reports to the home competent authority of the executing entity
- trading venues submit reports under Article 26(5) to the home competent authority of the trading venue
- where a trading venue is offering a service to an investment firm under Article 26(7) it must submit to the home competent authority of the investment firm
In relation to transaction reporting, order record keeping for trading venues and clock synchronisation, the following provisions will apply from 3 January 2018. Firms should understand the rules and guidance and how to apply it in practice:
- Markets in Financial Instrument Directive 2014/65/EU (MiFID)
- Markets in Financial Instruments Regulation (EU) No 600/2014 (MiFIR)
- Regulatory Standards for transaction reporting
- SUP 17A of the FCA Handbook
- MAR Market Conduct (MAR 9.5)
- The Guidelines on transaction reporting, order record keeping and clock synchronisation
- ESMA Questions & Answers on MiFIR data reporting
- SUP Transitional Provisions (TP 9)
Market participants should also ensure that they follow the schema validation, reporting instructions and the transaction reporting validations.
There is a transitional provision (SUP Transitional Provisions (TP 9)) that will continue to apply the provisions under MiFID I to transactions that took place before 3 January 2018. The provisions in SUP 17 and TRUP will therefore apply in respect of transactions executed prior to 3 January 2018.
Market Watch newsletter
Our Market Watch newsletter looks at market abuse risk, transaction reporting, suspicious transaction and order reporting, and other market conduct issues. It can help regulated firms and other non-regulated market users understand more about these areas and relevant practices to consider.
The latest newsletter (Market Watch 55) covers some important MiFID II requirements about reporting at the block or allocation level and transitional arrangements.
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