On 5 September 2022, the European Securities and Markets Authority (ESMA) updated its Questions and Answers on MiFID II and MIFIR transparency topics. The ESMA has added a new question in chapter 9 (third country issues) which asks whether transactions executed between a branch and its head office are subject to transparency requirements. The response states ‘no’ on the basis that transfers of financial instruments between two branches of the same legal entity or a branch and its parent company are not subject to the transparency or transaction reporting requirements, as they do not entail a change in the ownership of financial instruments.