ESMA MiFIR Review

Key Proposals & Dates

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Author Image Author: Sophia Fulugunya Sophia's LinkedIn
Director of Transaction Reporting
09 October 2024

ESMA has issued its fourth consultation package under the MiFIR Review, with a specific focus on amended RTS 22. This is a critical step in firms preparing for changes in reporting.

Key proposals include:

• Expanded Transaction Reporting Scope: As noted in amended Article 26 of MiFIR, the consultation proposes new rules for reporting OTC derivatives transactions, including those denominated in major currencies (EUR, USD, JPY, GBP) and subject to the clearing obligation.

• New Reporting Fields & Identifiers: Introduction of fields to capture the effective date of transactions, new identifiers for linking aggregated orders, and requirements for the reporting obligation entity.

• Alignment with International Standards: Field adjustments to harmonise MiFIR reporting with EMIR REFIT and global reporting frameworks, streamlining regulatory processes across jurisdictions.

Key dates

📅 Consultation deadline: 3 January 2025

📅 ESMA submission to the European Commission: Q1 2025

📅 Final standards expected: 29 September 2025


Engaging with consultations from regulatory bodies like ESMA is not just a compliance measure, it's a strategic opportunity for firms. Amongst other things it allows firms to voice concerns or provide insights that can shape the final regulations, ensuring they are practical and realistic for industry use.

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