T+1 Trouble?

A MiFID Checklist for US Firms Trading OTC Products in UK & Europe 

12 August 2025

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Led by former-FCA regulator Sophia Fulugunya, Qomply’s CPD accredited MiFID II Transaction Reporting 101 Training provides participants with a strong understanding of the transaction reporting requirements for MiFID investment firms.

US firms trading in the UK or EU may know MiFID II, but many remain unsure about T+1 transaction reporting requirements.

Under Article 26 of MiFIR, in-scope firms must report eligible trades to the FCA or another EU authority by 11:59 PM UTC on the day after execution. Reports must follow a strict XML schema, include 65+ mandatory fields, and pass multiple validations.

Missed or invalid reports—whether from scope confusion, technical issues, or bad data—can lead to regulatory scrutiny, costly back-reporting, and reputational harm.

Firms may fall in scope if they are MiFID-authorised, provide execution or order transmission services, or trade instruments listed in FIRDS.

This checklist offers seven key questions to help US firms confirm their MiFID II exposure, strengthen readiness, and avoid enforcement risk.

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