MiFID II Position & MiFIR Transaction Reporting within the EEX Compliance Services Framework

    The MiFID II / MiFIR functionality is aligned with the EEX’s Groups other regulatory reporting services for REMIT and EMIR using the same infrastructure, member access mechanisms as well as a common source of exchange, clearing and configuration data to best serve your needs.

    All exchanges of EEX Group are covered (CEGH, EEX, Gaspoint Nordic and PXE).

    Reporting Obligations

    Position Reporting

    • Exchanges are required to submit daily as well as weekly position reports to the National Competent Authorities (NCAs), e.g. BaFin/AMF (§58.1).
    • All exchange members are required to support position reporting by the trading venue (§ 58.3).
    • EEX Group’s exchanges will leverage ECC‘s position data and combine this information with instrument reference data and configuration data provided by the members to create draft MiFID II position reports.
    • In case the member does not provide any amended information within the defined timeframe, EEX Group will submit the generated draft MiFID II position report assuming that it is complete.

     

    Transaction Reporting (RTS22)

    • Exchanges are required to implement a daily reporting solution for non-investment and third-country firms (§ 26.5).
    • Non-investment and third-country firms are required to support the transaction reporting by the trading venue.
    • EEX Group’s exchanges will leverage ECC‘s position transaction data as well as order data from the trading system (T7) and combine this information with instrument reference and configuration data provided by the members to create a draft MiFIR transaction report.
    • In case the member does not provide amended information within the defined timeframe, EEX Group will submit the generated draft MiFIR transaction report assuming that it is correct.
    • Investment firms are required to submit a transaction report to the National Competent Authority (NCA) of the trading venue. (The draft based approach described above can also be offered as a service to investment firms.) Please note that investment firms have to fulfil more complex end client related requirements that are not covered within the draft reports. Therefore, investment firms have to implement additional measures.
    Title Type Category Publishing date File
    MiFID II/MiFIR Data Services Agreement Regulatory Reporting MiFID II / MiFIR Registration / Starter Kit 2020-05-11 pdf (618 KB)
    MiFID II/MiFIR Customer Acknowledgement sample Regulatory Reporting MiFID II / MiFIR Registration / Starter Kit 2019-11-06 zip (4 KB)
    Customer Acknowledgements - MiFID II/MiFIR Reporting Regulatory Reporting MiFID II / MiFIR Registration / Starter Kit 2019-02-07 pdf (1 MB)
    MiFID II/MiFIR Data Services Description Regulatory Reporting MiFID II / MiFIR Registration / Starter Kit 2018-06-07 pdf (2 MB)
    MiFID Instrument File sample + explanation Regulatory Reporting MiFID II / MiFIR Registration / Starter Kit 2018-02-09 zip (691 KB)

    Position Reporting – Overview

    • As part of MiFID II, there is an obligation for EEX to submit a daily/weekly position report to the relevant National Competent Authorities (NCAs), e.g. BaFin/AMF (Article 58, paragraph 1).
      • EEX will leverage ECC position data to generate a draft report with all the information available for each exchange member (NCM)
    • Exchange members are required to support the position reporting of the trading venues (Article 58, paragraph 3) and can do so using the regulatory reporting solution of EEX Group.
      • Members can access and amend the draft reports provided by the regulatory reporting service of EEX Group.
      • Members only need to contribute additional information not available to the exchange (for non-investment firms this will include the hedge/spec flag).
      • Investment firms have the obligation to submit own position reports to NCAs
      • Split-up of positions on client level can be created based on the draft reports generated by EEX.
      • Reporting of off-exchange positions is supported (for derivatives listed at EEX).

    Position Reporting – Standard Workflow

    • Reports are automatically generated based on ECC position data, member static data and default values provided by the member.
    • EEX provides draft reports for amendment or replacement by the member on SFTP.
    • Members can optionally amend report data.
    • Reports are automatically submitted to the National Competent Authority (NCA)  using the access infrastructure of the Regulatory Reporting Hub (RRH) of Deutsche Börse AG.

    Members are required to provide additional member-related static data (one-off task) according to the definition in ESMA’s  ITS4 (see attachment):

    • Member LEI/National ID
    • Member Status (IF/None-IF)
    • Email
    • Ultimate Parent LEI/National ID
    • Ultimate Parent Email
    • Parent of Collective Investment Scheme Status
    • Risk-reducing default
    • EEX will provide the instrument static data needed for the report creation

    For details regarding the instrument static data file, please refer to the document "Instrument File for MIFID II / MiFIR".

    EEX will prepare a full position report in the ITS4 format:

    • Using the extended FCA schema provided by FIA
    • Based on ECC position data with all information available to the exchange
      • For the hedge vs. speculative default, members can provide a global default value

    The draft report will always be based on the assumption that the relevant Non-Clearing Member (NCM) is the end-client in accordance with the regulation.

    • Members can download the draft reports prepared by EEX, make amendments and upload new versions. (Report uploads must use the full ITS4 format and include all records.)
    • The timeline for modifications is still under discussion (current assumption 10:00 – 14:00 CET).
    • EEX uses the Deutsche Börse AG Regulatory Reporting Hub (RRH) service for the submission of position reports to the National Competent Authorities (NCAs)
    • Investment firms can opt for direct reporting to the Regulatory Reporting Hub (RRH) (subject to corresponding contractual agreements with EEX and Deutsche Börse AG)

    So far the Financial Conduct Authority of Great Britain (FCA) is the only National Competent Authority (NCA) with a published ITS4 adaptation (xml schema and reporting guideline):

    • Other NCAs (e.g. BaFin/AMF) have not yet published technical interface specifications or a schema file.
    • EEX will suggest the usage of the FCA schema to our relevant NCAs, BaFin and AMF and therefore bases it’s planning activity on this structure.

    FIA and EFET have jointly published a Position Reporting Schema based on multiple workshops with industry partners to cover the member to exchange position reporting. (This is based on the FCA’s position reporting schema used for the exchange to NCA communication.):

    • Full consistency for all attributes included in the FCA schema
    • Additional (optional) attributes added where required by trading venues or firms for internal processes

    EEX will use the “Extended FCA” schema for data exchange with the members and assumes that the original FCA schema can be used for data exchange with all relevant NCAs.


    Title Type Category Publishing date File
    Examples MiFID Reporting EEX Group Regulatory Reporting MiFID II / MiFIR Position Reporting 2017-12-14 zip (173 KB)
    ITS4 Schema File (With Extensions) and Sample Files Regulatory Reporting MiFID II / MiFIR Position Reporting 2017-09-29 zip (8 KB)
    ITS4 final version (esma70-872942901-3_final_report_-_draft_its_4.pdf) Regulatory Reporting MiFID II / MiFIR Position Reporting 2017-07-24 pdf (364 KB)

    Transaction Reporting - Overview

    As part of MiFIR, there is an obligation for EEX Group exchanges to submit a daily transaction report for non-investment firms and third-country firms to the relevant National Competent Authorities (NCAs), i.e. BaFin/AMF (§ 26.5, RTS 22).

    • EEX Group will leverage ECC‘s position transaction data as well as order data from the trading system (T7) and combine this information with instrument reference data and configuration data provided by the members to create a draft MiFIR transaction report.

    Applicable exchange members are required to support the transaction reporting of the trading venues and can do so using the regulatory reporting solution of EEX Group.

    • Members can access and amend the draft reports provided by the regulatory reporting service of EEX Group
    • Applicable members only need to contribute additional information not available to the exchange (In the case of exchange trades executed on the continuous market, this is usually the hedge/spec flag which can be entered at order level, but can also be amended on T+1 up to an early afternoon deadline)

    Investment firms have the obligation to create MiFIR transaction reports. For investment firms EEX Group will be able to offer the same draft report creation service as stated above. None-the-less it is assumed that an investment firm might have more complex amendment requirements and in addition to the draft reports, further measures have to be implemented.

     

    Transaction Reporting - Standard Workflow

    • Reports are automatically generated based on ECC position transaction data, member static data and default values provided by the member
    • EEX provides draft reports for amendment or replacement by the member on SFTP
    • Members can optionally amend report data
    • Reports are submitted automatically to the National Competent Authority (NCA) using the access infrastructure of the Regulatory Hub of Deutsche Börse AG in time to meet reporting deadlines

    Members are required to provide additional member-related static data (one-off task):

    • Member LEI/National ID
    • Member Status (IF/None-IF)
    • Risk-reducing default
    • Usually only for investment firms: Short-code translation details – Deutsche Börse AG based infrastructure defined in the context of exchange trading on T7 trading system and RTS 24 (order audit trail) related data provision requirements, see documentation and link section for more details.
    • EEX will provide the instrument static data needed for the report creation

    For details regarding the instrument static data file, please refer to the document "Instrument File for MIFID II / MiFIR".

    EEX will prepare a full transaction report in a format compatible with Deutsche Börse Group’s RRH’s (Regulatory Reporting Hub) transaction reporting layout:

    • Based on ECC position transaction data as well as T7 order data:
      • If members do not use the hedge / speculative related flag at order entry level, EEX Group will use the hedge speculative default, members can opt for all speculative or all hedge.
    • Members can download the draft reports prepared by EEX, make amendments and upload new versions (If EEX Group has the reporting obligation report uploads must include the full set of records.)
    • The timeline for modifications is still under discussion (current assumption 10:00 – 14:00 CET).
    • EEX uses the Deutsche Börse AG Regulatory Reporting Hub (RRH) service for the submission of transaction reports to the NCAs.
    • Investment firms can opt for direct reporting to Deutsche Börse Group’s Regulatory Reporting Hub (RRH) (subject to corresponding contractual agreements with EEX and Deutsche Börse AG).
    • The schema applicable for the EEX Group’s draft file and the SFTP file upload is based on the existing Deutsche Börse AG Regulatory Reporting Hub (RRH) transaction reporting schema

    Download Transaction Reporting Schema


    Title Type Category Publishing date File
    MIFID II EEX Group - Transaction Reporting Schema XSD_v1.3 Regulatory Reporting MiFID II / MiFIR Transaction Reporting 2018-04-03 zip (2 MB)
    Examples MiFID Reporting EEX Group Regulatory Reporting MiFID II / MiFIR Position Reporting 2017-12-14 zip (173 KB)
    RTS 22 (European Commission) Regulatory Reporting MiFID II / MiFIR Transaction Reporting 2017-07-24 pdf (286 KB)
    RTS 22 – annex (European Commission) Regulatory Reporting MiFID II / MiFIR Transaction Reporting 2017-07-24 pdf (586 KB)

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    The information on this website does not provide or substitute legal advice!

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