Preparing for BREXIT

Brexit - What Regulatory Reporting Clients Need to Know

What is BREXIT? When does it start?

The UK is no longer a member of the European Union (EU) and the Transition Period is scheduled to last until 31 December 2020. The deadline is fast approaching to agree the rules for the new UK-EU relationship. The changes will affect many areas, including regulatory reporting, and will start on 1 January 2021. Given that 1 January is a public holiday the effective start date will be 4 January 2021.

What happens if there's no trade deal by 31 December?

When transition ends on 31 December, if there is no trade deal, the UK will automatically drop out of the EU's main trading arrangements (the single market and the customs union). In any case, we want to assure our clients that post-Brexit, UnaVista will continue to provide fully compliant reporting solutions in both the UK and the EU.

We have already been writing to our clients informing them of changes we are implementing to UnaVista’s Trade Repository services, Transaction Reporting services as well as the associated fee changes. These changes are being made so we can continue to provide Trade Repository and MiFIR Transaction Reporting services for our customers with minimum disruption, as a result of the departure of the United Kingdom from the European Union and the upcoming end of the transition period (Brexit).

Ongoing provision of EU and UK transaction reporting services

A new company, UnaVista TRADEcho B.V., an affiliate of London Stock Exchange plc and ultimately wholly-owned by London Stock Exchange Group plc, has been incorporated and is headquartered in Amsterdam. UnaVista TRADEcho B.V., has obtained regulatory approval from the relevant regulators in order to provide (MiFIR. EMIR, SFTR) transaction reporting and trade repository services, where applicable.

What happens between now and BREXIT for my reporting?

UnaVista is here to work with you and help you prepare for the transition. With that in mind, UnaVista will be hosting a number of client working groups and update calls to help you understand the steps you need to take. We will help explain who is impacted, what technical changes you might have to make (if any) and provide timelines. Please refer to the information on this page for any updates or contact your UnaVista account manager. 

Which regulations does it impact?

Clients reporting under MiFIR, EMIR and SFTR might be affected. Further information is provided in relevant sections below.

 

MIFIR

We are preparing for post Brexit state where there is no data sharing arrangements between the FCA and EU27 regulators. Please find below a summary of operational activities and details of our next working groups where you can find out more:

MiFIR ARM

RTS22 Transaction Reporting:
UnaVista will switch on the EU ARM service operated by UnaVista TRADEcho BV (Submitting Entity field will use the LEI of UnaVista TRADEcho BV) for reporting to all EU27 regulators during the week of Monday 14 December 2020. The switch on will take place in a phased approach by NCA and we will publish a detailed run-book for that week shortly. This means that RTS22 transition reports will be separated by EU and UK following that date. We have decided to turn on the EU ARM service in advance of Brexit to avoid the risk of a single go live on Monday 4 January 2021. 

For EU service customers – the table detailing connectivity status to all EU27 regulators is available here: NCA Connectivity Progress

Post Brexit RTS22 state is available to test in UAT now.   

Client access to MiFIR Reporting UAT: Click here to login

Client access to MiFIR Rules Engine UAT: Click here to login

Venue Data Collection:
Venue Data Collection is a service where we provide transaction reports to Trading Venues on behalf of their third country members.  We are in the process of re-testing all venue connections and will publish a table summarising status of each connection shortly. This service will be put in production for Monday 4 January 2021. Please note that most Trading Venues (with exception of CBOE) provide response files directly to their members, bypassing UnaVista. It is our intention to work with the Venues to process responses in UnaVista post Brexit.
 
Venue Data Collection is available to test in UAT now, however some Trading Venues do not have their UAT environments ready. A document pack for this solution, including a list of Trading Venues available for testing will be published shortly. We will also book a working group for all impacted firms.
 
Duplicate Reporting Domains:
In some cases of branch and transmission of orders reporting a duplicate (or dual) reporting domain is needed.  Please note that we cannot put Duplicate Domains into production until the end of transition period, as doing so would result in over-reporting. Should you require a new Duplicate Domain, please contact your account manager now.
 
Duplicate Domains use standard ARM functionality and should be available for set-up and testing in UAT now.

EU/UK Eligibility Reference Data:

For clients receiving eligibility files, UnaVista will be  publishing two distinct RTS22 eligibility reference files for EU and UK. All current clients will receive the UK files by default unless you contact your account manager to request either EU or both.

Separate UK/EU reference files are available now for testing purposes. Please contact your account manager should you want start receiving and using them. Details are available here: MiFIR Brexit Reference Data Document Pack
 
UnaVista RTS22 Eligibility Module:
Clients using UnaVista to determine their eligibility, will be automatically switched over to the respective EU/UK service during the week of 14 December 2020.  No action from firms is required.

UnaVista based EU/UK eligibility will be available for testing 9 November 2020 UAT and deployed into production on 30 November 2020. (Release 2.0.1)

Resources
Should you require any additional services in preparation for Brexit, please contact your account manager.
For onboarding and UAT testing support for any of the above please contact UVClientintegration@lseg.com
Our Brexit doc pack, which contain latest versions of all available  documents and will be updated as we go is available here: Brexit Technical Document Pack

 
MiFIR Working Groups
We will be hosting a number of working groups, part of the agenda will be on Brexit to help you prepare and ask questions about the above. Please register via the link below.


MiFIR Client Working Groups:

MiFIR - Venue Data Collection Working Group

MiFIR - Client Working Group & Brexit Update 

 

EMIR

We are preparing for post Brexit state where there is no data sharing arrangements between the FCA and EU27 regulators.  Please find below a summary of operational activities and details of our next working groups where you can find out more:

EMIR TR
The current plan for relevant trade repositories is that their content will be replicated into production UK EMIR on the weekend of 1 January 2021, with first UK reports accepted on Monday 4 January 2021.  Firms will be automatically onboarded to relevant TR. 
 
Firms need to connect through the right entry point to either EU or UK TR.  Please refer to the F&Q document in the Brexit Technical Document Pack

EMIR UK TR is available for testing now.  Production will only be available on Brexit date.

Client link to access the UKMIR UAT system: Click here to login.

Client link to access the EMIR UAT system: Click here to login

 
Resources
Should you require any additional services in preparation for Brexit, please contact your account manager.

For onboarding and UAT testing support for any of the above please contact UVClientintegration@lseg.com

Our Brexit doc pack, which contain latest versions of all available  documents and will be updated as we go is available here: Brexit Technical Document Pack

Working Groups
We are holding a number of working groups, part of the agenda will be on Brexit to help you prepare and ask questions about the above. Please register via the link below.

EMIR Client Working Group
Date: 22 October 2020 at 16:00
Click here for full details

 

SFTR

We are preparing for post Brexit state where there is no data sharing arrangements between the FCA and EU27 regulators.  Please find below a summary of operational activities and details of our next working groups where you can find out more:

SFTR TR
The current plan for SFTR trade repositories is that their content will be replicated into production UK SFTR TR on the weekend of 1 January 2021, with first UK reports accepted on Monday 4 January 2021.  Firms will be automatically onboarded to the relevant TR. 
 
Firms need to connect through the right entry point to either EU or UK TR.  Please refer to the F&Q document in the Brexit Technical Document Pack

UK TR is available for testing now.  Production will only be available on Brexit date.

Resources
Should you require any additional services in preparation for Brexit, please contact your account manager.

For onboarding and UAT testing support for any of the above please contact UVClientintegration@lseg.com

Our Brexit doc pack, which contain latest versions of all available  documents and will be updated as we go is available here: Brexit Technical Document Pack

Working Groups
We are holding a number of working groups, part of the agenda will be on Brexit to help you prepare and ask questions about the above. Please register via the link below.

SFTR Brexit for Rules Engine (design decisions) - For Rules Engine Clients Only
Date: 23 October 2020 at 12:00
Click here for full details

SFTR Brexit Working Group
Date: 05 November 2020 at 16:00 
Click here for full details