On 28 September 2020, the European Securities and Markets Authority (ESMA) announced that it had updated its Q&A document on data reporting under MiFIR.

ESMA explains that it has updated the Q&A as follows:

  • Section 2: LEI of the issuer. A new Q&A (question 6, LEI of funds) that seeks to clarify which LEI (ISO 17 442 Legal Entity Identifier) should be used to identify the “issuer” when reporting reference data on funds to FIRDS under Article 4 Market Abuse Regulation and Article 27 MiFIR.
  • Section 22: transaction reporting. Questions 2 and 13 are updated. The amendment to question 2 relates to the Q&A on national client identifiers for natural persons clarifying how different national identifiers specified in Annex II of RTS 22 are represented. The amendments also provide clarification on the requirements for Swedish national client identifiers. The amendment to question 13 provides clarifications in relation to the reporting requirements under Article 26 of MiFIR and RTS 22 (Commission Delegated Regulation (EU) 2017/590). The amendment provides an additional reporting scenario to an existing Q&A where an investment firm executes a transaction through an execution algorithm using the membership of its client to execute the order in the market.