What is MiFID II Transaction Reporting?

MiFID II Transaction Reporting is a regulatory framework in the EU and UK that requires investment firms to submit complete and accurate transaction details of their transaction reports to the competent authorities by the end of the following working day (T+1).

Contact Qomply

Former FCA regulator, Sophia Fulugunya discusses the challenges firms face with MiFID II Transaction Reporting requirements.

About MiFID II

The Markets in Financial Instruments Directive (MiFID II) came into effect on 3 January 2018 across the EU and UK, marking the introduction of one of the most comprehensive financial regulations since the 2008 financial crisis. This new transaction reporting regime replaced the initial MiFID introduced in 2007 and was viewed as far more thorough yet complex.

MiFID II's primary objective is to provide regulatory authorities with comprehensive data on financial transactions related to instruments listed on trading venues and those executed with an SI. For EU MiFIR, this applies to EU trading venues (RM, MTF, OTFs) and Sis, whilst for the UK equivalent it applies to instruments traded on UK, EU and Gibraltar trading venues and SIs. This data is vital to the regulators market monitoring and surveillance efforts, ensuring the markets function well and ultimately protect investors.

European Securities and Markets Authority (ESMA), is responsible for the regulation in Europe whilst it’s counterpart, the Financial Conduct Authority (FCA), supervises the regime in the UK post-Brexit. Since 2021, there have been a number of discussion and consultation papers released by the two regulators regarding revisions to MiFID II that points towards a divergence between the two regulators.

ESMA has been the first of the two to provide concrete changes and on 27 March 2024 released a formal Public Statement announcing a move to formally apply the findings of their MiFID review with a series of substantive changes. The deadline for the transposition of amendments is 29 September 2025. Saying that, ESMA put a hold on changes to the Regulatory Technical Standards (RTS) pending a call for evidence launched in June 2025 aiming to streamline transaction reporting. The European regulator aims to publish the final report from the feedback received in early 2026.

The FCA, in conjunction with HM Treasury, published a Discussion Paper on “Improving the UK Transaction Reporting Regime”. This was open for feedback until 14 February 2025, with a Consultation Paper expected at some point in 2025. The outcome of this consultation process may result in divergence from the EU, although the full extent of is unlikely to be known until 2026.

This is a clear indication that MiFID II and its successor will continue to pose challenges for firms despite regulatory messaging emphasising simplification, harmonisation, and burden reduction.

FAQ: MiFID II Transaction Reporting

A transaction report must be submitted following the execution of a transaction in a reportable instrument. Complete and accurate details must be submitted to the relevant competent authority (the FCA in the UK). This requirement is set out in Article 26(1) of the Markets in Financial Instruments Regulation (MiFIR). The UK version, which is currently very similar to the EU version, became UK legislation following the implementation of the European Union Withdrawal Act post-Brexit. Since then, however, there has been increasing regulatory divergence.
Generally, the following categories of firms are required to submit transaction reports each submitting to the respective regulators in the EU and UK:
    - MiFID investment firms, including branches of third country investment firms (excluding collective portfolio management investment firms).
    - Operators of a trading venue (recognised investment exchanges, multilateral trading facilities (MTFs) and organised trading facilities (OTFs)).
For principal firms with appointed representatives (ARs), the obligation to report sits with the principal firm in relation to any reportable activity conducted by its ARs.
Article 26(1) UK MiFIR requires an investment firm to submit a transaction report for transactions it executes in financial instruments by the end of the following working day (T+1). An investment firm is deemed to have executed a transaction where it provides any of the services set out in Article 3 of RTS 22. A transaction must be submitted regardless of whether it took place on a trading venue or not.
To provide regulatory authorities, such as the FCA and ESMA, with the data required to conduct market surveillance, monitor systemic risk and ultimately protect investors.
UK MiFID firms with the technical capabilities and systems to do so, can submit straight to the FCA’s Market Data Processor (MDP). For smaller firms, in most instances, this may be beyond their means. An alternative option is to submit to the FCA via an Approved Reporting Mechanism (ARM). However, depending on your trading volume, using such a provider my not be cost effective.
There is the distinct possibility of future regulatory divergence between the UK and the EU when it comes to MiFID II / MiFIR transaction reporting. This is likely to make it more difficult for firms to stay compliant with both regimes. In the UK both HM Treasury and the FCA have published Discussion Papers, with the latter having closed on 14 February 2025. This is likely to be followed up by a Consultation Paper at some point in 2025 – although this has not yet materialised. It is therefore likely any final rule changes would not be implemented in the UK until 2027.

Rely On Qomply To Help

Qomply has a variety of solutions to help firms comply with their regulatory MiFID transaction reporting requirements as mandated under RTS 22, Article 15 of MiFIR:

QomplyEngine generates mifid transaction reports

QomplyEngine - Generate Transaction Reports From Raw Data


Builds transaction reports from raw data points and saves resources and hassle by offloading transaction report generation.
Quality Assurance for Transaction Reports

Diagnostic Auditor - Ensure Reports Are Accurate


Apply over 1,000 accuracy checks and scenarios across your Transaction Reporting in a click and comply with RTS22, Article 15 of MiFIR Testing.
Reconcile MiFID Transaction Reports

Trade Reconciliation - Ensure Front-Office Data Matches Data Sent to Regulator


Ensure reports are complete and reconcile with data sent to the regulator. Instantly reconcile large data sets in seconds and comply with RTS22, Article 15 of MiFIR Reconciliation.
QomplyDirect send reports directly to the FCA

QomplyDirect - Submit Reports Directly to Regulator


Send Transaction Reports directly to the regulator bypassing the need to use an ARM, reducing costs and improving efficiency.
Outsource your MiFID Report Operations

Qomply Managed Services - Delegate Your Transaction Reporting Operations to Qomply


Qomply Managed Service alleviates the burden of technical expertise while providing 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
● MiFID II: Top 5 Transaction Reporting Error Codes
● Transaction Reporting Cheat Sheet
● MiFID II Deep Dive: Following Market Conventions in the Absense of Prescribed Guidance

External Resources

● MiFID II Directive | ESMA
● MiFIR Regulation | ESMA
● RTS 22
● Reporting Guidelines | ESMA
● ESMA Validation rules (2022)
● FCA Transaction Reporting webpage
● ESMA OTC derivatives traded on a trading venue

More Reporting Regimes

● MiFID II Post-Trade 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

Request a Demo

Let's Get In Touch!

Want to know more or just want to phone us up for a chat?

+44 (0)20 8242 4789

info@qomply.co.uk

Qomply

© Copyright 2025 Qomply

Qomply is the trading name of Qomply Limited and is a private limited company registered in England and Wales with registered number 12082474, VAT Number 357 7105 86 and registered address: 133-137 Fetter Lane, London, EC4A 1BF, UK.