As we approach the festive period, please be aware that transaction reporting deadlines will adjust around public holidays. We have included below a reporting schedule for the holiday period.
FCA MiFIR Transaction Reporting
DATE OF EXECUTION
DATE OF REPORTING
Reports pertaining to transactions that occurred on December 24 should reach the FCA no later than the close of the next working day. Since December 28 will be the substitute Boxing Day, transactions that happened on December 24 and indeed on December 28 (since some markets will be open) should reach the FCA by the close of December 29.
In practice, reporting firms that use the service of an Approved Reporting Mechanism (ARM) should ensure that transactions which occurred between December 24 and 28 reach the ARM before the end of December 29 so that the ARM can in turn submit them to the FCA.
With respect to January 1, transactions that occurred on December 31 should reach the FCA no later than the close of the next working day, therefore January 4. ARMs will be open on January 4 so as to comply with the above.
UK EMIR Trade Reporting during the festive period
EMIR reporting during the festive period follows the same logic as for MiFIR transaction reporting where firms should look at non-working days as per their local NCA and report transactions no later than the close of the next working day.
Firms should also check whether the trade repository is opened for business even if the day is considered a non-working by the local NCA or otherwise considered a working day by the local NCA but the trade repository is closed.
As an example, UnaVista's Trade Repository (TR) will be closed between 23:00 on December 31 and 22:00 on January 3.
UK firms that have been using UnaVista's UK TR up to December 31 and will continue to do so after the end of the Brexit transition period will have until the end of January 4 to submit the file relevant to their December 31 activity.
16 December - 2 January
FCA FIRDS will be unavailable
FCA FIRDS will produce ESMA’s complete FIRDS dataset
FCA FIRDS will produce a delta file which will contain UK listed instruments
31 December - 7 January
ESMA FIRDS will be unavailable
FCA’s FIRDS system will be unavailable between December 16 and January 2 (14:00 GMT) as it prepares for Brexit work. On January 2, the FCA FIRDS will produce ESMA’s complete FIRDS dataset.
On January 4 (08:00 GMT) they will produce a delta file which will contain UK listed instruments (dual listed instruments will be under GB as the relevant competent authority only) and EU27 listed only instruments.
ESMA on the other hand will shut their FIRDS system down between December 31 (21:30 CET) and January 7 (12:00 CET (Noon)).
EEA Investment Firms shall continue to use the FIRDS dataset published on January 31 and any transaction reports on missing instruments will be in a ‘pending’ state with the NCAs.
On January 7, the delta file will contain the termination of UK financial instruments and update of the relevant competent authority on dual listed instruments whereas the full file will contain all instruments still active in the EU27 trading venues.
Note: The information on this page represents SteelEye’s sole interpretation of the regulatory guidelines and updates and should not be relied on in any way. This interpretation is not legal advice. Always consult your compliance and legal team before making any changes to your regulatory operations.