Regulatory Reporting | MiFID II Post-Trade Transparency Reporting

What is MiFID II Post-Trade Transparency Reporting?

First introduced in 2007 and revised in 2018, the EU and UK's Markets in Financial Instruments Directive (MiFID II) aims to enhance market resilience, transparency, and investor protection. Under MiFID II Post-Trade Transparency Reporting, investment firms must provide complete and accurate trade details to an Approved Publication Arrangement (APA) for publication.

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Former regulator, Sophia Fulugunya, discusses the challenges firms face with Trade Reporting requirements.

About MiFID II Post-Trade Transparency

To promote market resilience and transparency, MiFID II outlines a series of Articles and technical standards which must be adhered to; these apply to all EU trading venues (RM, MTF, OTF), SIs and UK equivalents.

Post-Trade Transparency Reporting is outlined in RTS 1 and RTS 2 of MiFIR:

  • Near real-time market reporting via the Financial Information eXchange (FIX)
  • Reports to be sent to the APA within 1-min for equity (and equity-like products) and within 5-min for non-equity products
  • 20+ Required fields such as Trading Date and Time, ISIN, Price, Venue of Execution and more

These reports are then anonymised, aggregated and published by the APA with the ultimate goal being to promote transparency between market participants.

The regulation is the responsibility of the European Securities and Markets Authority (ESMA) and is enforced in the UK by the Financial Conduct Authority (FCA). Post-Brexit, since 2021, the two regulators are increasingly divergent, releasing a series of consultation papers detailing the region-specific differences in reporting.

FAQ: MiFID II Post-Trade Transparency

Post-Trade Transparency under MiFID II mandates that certain key details of securities transactions are made public immediately after the trade is executed. The purpose of this is to increase transparency for market participants, as well as to enable the relevant competent authority to monitor systemic risk and market abuse. Post-trade reporting also ensures the data is available on a non-discriminatory basis, by ensuring the data is provided in a standardised format.
All market participants, including investment firms, trading venues, sell-side entities, and systematic internalisers are required to report post-trade transaction details. This applies to any financial instrument traded on EU-regulated markets, multilateral trading facilities, organized trading facilities, and certain over-the-counter transactions.
Enhanced post-trade transparency helps increase market integrity by providing investors with timely and accurate trade data, fostering better market surveillance, and promoting more informed investment decisions, thereby protecting investor interests and improving market confidence.
Reports must be submitted to an Approved Publication Arrangement (APA) and include comprehensive details such as the financial instrument, the price, the quantity, and the execution time of the trade. This information is then aggregated and published to ensure accessibility and transparency for all.
An APA plays a critical role in MiFID II compliance by collecting and disseminating trade reports on behalf of investment firms. They ensure that trade information is standardised and published in a manner that is accessible and useful to the public and market participants. APAs do this to enhance market transparency and aid regulatory oversight.
A post-trade transparency report under MiFID II must include the type of financial instrument, the quantity traded, the execution time, the price, and the identity of the trading venue. This detailed reporting ensures that all market participants have a clear and comprehensive view of trading activity, fostering greater market transparency.

Rely On Qomply To Help

Qomply has a variety of solutions to help firms comply with their regulatory MiFID II Post-Trade Transparency Reporting requirements:

QomplyEngine generates mifid transaction reports

QomplyEngine - Generate Transaction Reports From Raw Data


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Quality Assurance for Transaction Reports

Post-Trade Diagnostic Auditor - Ensure Reports Are Accurate


Apply 100+ accuracy, scenario-level and best practice checks across your Post-Trade Transparency Reports in a click and comply with MiFID II requirements
Find reportable ISINs

ISIN Quest - Find ISINs Instantly


Improve your MIFID reporting by easily retrieving reportable ISINs for your transactions through Qomply's ISIN Quest
Outsource your MiFID II Post-Trade Transparency Report Operations

Qomply Managed Services - Delegate Your Transaction Reporting Operations to Qomply


Qomply Managed Service alleviates the burden of technical expertise but also provides peace of mind that regulatory requirements are being met in a risk-free and cost-effective manner

Free MiFID Resources

● MiFID Guide: The Silent Errors in Your MiFID Transaction Reports
● MiFID Guide: Transaction Reporting Reconciliation 101
● Free Tool: MDP XML to CSV Converter
● Free Tool: MiFID Reportability Look Up Tool
● Free Tool: Instantly Retrieve Reportable ISINs

External Resources

● MiFID II Post-Trade Transparency Manual | ESMA
● MIFID II Final Report on Post-Trade Transparency | ESMA
● Technical Standards under MiFID II and MiFIR | FCA
● Reporting Guidelines | ESMA
● RTS 1
● RTS 2
● MiFID II Post-Trade Transparency Manual | ESMA
● RTS 1 Annex
● RTS 2 Annex

More Reporting Regimes

● MiFID II Transaction Reporting 101
● EMIR Refit Transaction Reporting 101
● CFTC Transaction Reporting 101
● CSA Transaction Reporting 101
● MAS Transaction Reporting 101
● SFTR Transaction Reporting 101
● ASIC Transaction Reporting 101

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