ESMA - Q&A document on data reporting under MiFIR

ESMA has published an updated Q&A document on data reporting under MiFIR.

The updated Q&As document includes a new Q&A and two amendments to existing Q&As:

  • The newly added Q&A clarifies which LEI should be used to identify the “issuer” when reporting reference data on funds to FIRDS under MAR Article 4 and MiFIR Article 27. ESMA has observed that the lack of a public Q&A on this matter created uncertainty and resulted in inconsistent reporting of the LEI in the “issuer” field of the reference data report. Due to higher operational complexities related to changed reporting practices in some jurisdictions, this Q&A should be implemented six months after its publication.
  • The first amended Q&A provides clarifications in relation to the reporting requirements under Art. 26 of MiFIR and RTS 22. The Q&A 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.
  • The second amended Q&A relates to the Q&A on national client identifiers for natural persons clarifying on 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 UnaVista ARM itself is updated to ensure that all data validations are in line with ESMA’s guidelines. In addition, UnaVista can assist clients with their reconciliations and also provides a product eligibility service to ensure clients report the correct products. Further UnaVista Analytics, to be released shortly, contains Alerts designed to highlight reporting errors and dashboards to facilitate analysis of reported data to ensure that some of the common errors made and commented on by regulators can be caught quickly and avoided by firms.

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