EMIR Refit | Navigating the Details

Author: Sophia Fulugunya
Director of Transaction Reporting
27 June 2023
Updated 5 March 2024

Many regulatory reporting teams are cross-functional and may be involved in implementation of various regimes including MiFIR and EMIR. Whilst familiarity of multiple reporting regimes may be of benefit in aiding understanding of the requirements, there are some distinct differences between seemingly similar fields and the expectations of the required data.

Reporting Tracking Number is not a TVTIC

ESMA is careful to point out that the Report Tracking Number (RTN) is not a one-to-one link with a TVTIC (Trading Venue Transaction Identification Code). TVTICs are transaction-level identifiers and are disseminated to both counterparties – buyer and seller – by a trading venue. RTNs are execution-level identifiers used to identify reports relating to the same execution. The RTNs are provided by investment firms, clearing members or CCPs.

Qomply's conversations with trading venues have revealed varying approaches to the construction of the RTN. Some venues are opting to concatate their LEI number with their current TVTIC to construct the RTN. Other venues are devising an alternative methodology of constructing an entirely new RTN number that is different from other transaction identification numbers used in the past.

There are still some outstanding questions regarding the generation and dissemination of the RTNs which we hope are clarified by the regulators in the upcoming months. In the meantime, it is important not to draw an association between TVTICs function and the function of RTNs in reporting.