On 29 July 2019, the European Securities and Markets Authority (ESMA) published an updated version of its Q&As on MiFIR data reporting. The updated Q&As insert a new question and answer within section 5 – Maturity Date, expiry date and termination date:

• What date should be populated in Field 24 (Expiry date) of RTS 23 for financial instruments without a defined expiry date [e.g. perpetual FX Rolling Spot Futures] for which the population of Field 24 is mandatory according to the CFI validation rules?

For instruments without a defined expiry date for which the population of Field 24 (Expiry date) is mandatory according to the CFI validation rules [e.g. perpetual FX Rolling Spot Futures] Field 24 should be populated with the value 9999-12-31 (in accordance with the ISO format). In case the expiry date becomes determined during the life cycle of the financial instrument Field 24 should be updated accordingly.