Reporting post-Brexit

Brexit - What Regulatory Reporting Clients Need to Know

What is BREXIT? When did it start?

The UK is no longer a member of the European Union (EU) and the Transition Period ended on 31 December 2020. The changes affected many areas, including regulatory reporting, and started on 1 January 2021. Given that 1 January was a public holiday, the effective start date was 4 January 2021.

What happens after 31 December?

Please note that the post-Brexit trade deal between the UK and the EU announced on 24 December 2020 does not impact UnaVista’s Brexit plans. 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. Please read further information (below) relevant to either MiFIR, EMIR or SFTR, where applicable.

We have already communicated to our clients informing them of changes we have implemented to UnaVista’s Trade Repository services, Transaction Reporting services as well as the corresponding commercial 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 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.

Legal structure UnaVista TRADEcho B.V.

Which regulations does it impact?

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

 

MIFIR

We are in a 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:

Please note that for firms back reporting to UnaVista EU ARM, we recommend that you pause submitting back reports till EU regulators issue more guidance on use of Pre / Post Brexit validations of venues and financial instruments.

MiFIR ARM

RTS22 Transaction Reporting:
UnaVista turned 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. This means that RTS22 transaction 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

Important MiFIR Brexit updates – last updated on 12 December 2020

ARM:

-  Please note that EU ARM back reporting will require adjustment to reflect both pre and post Brexit validations for transaction conduced on UK venues. More details coming shortly.

-  For any new duplicate or venue reporting domains please note that, unless you have already made bespoke rules engine arrangements,  UnaVista expects the firms to pre-filter and send separate dedicated flows in to each domain.

RTS23:

-  Please note that because of over a month long firm-NCA accreditation testing schedule, we currently cannot support any new RTS 23 connections in time for Brexit.

ARM Reconciliations:

-  Please note that as the only current NCA reconciliation is with the FCA, at present is no EU ARM Reconciliation service.  For FCA – dual domains require dual reconciliations domains.

Eligibility Files and Rules Engine Module:

-  Please note that, unless you explicitly notify us - all firms receiving eligibility files, using UnaVista Eligibility module or using a bespoke eligibility logic – have been switched to UK-FCA eligibility files and service.  Should you require EU eligibility or both – you must notify your account manager.

Please make use of the testing environments available

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.
 
Duplicate Reporting Domains:
In some cases of branch and transmission of orders reporting a duplicate (or dual) reporting domain is needed. 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 is now publishing two distinct RTS22 eligibility reference files for EU and UK. All current clients received 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, were 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 was 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 Technical Document Pack, which contains latest versions of all available documents and will be updated as we go is available on request. For more information, please contact your Account Manager at UnaVista.

 
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 & Brexit Updates: 

Click here for full details 

 

EMIR

We are now in a 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 approach for relevant trade repositories was that their content was replicated into production UK EMIR on the weekend of 1 January 2021, with first UK reports accepted on Monday 4 January 2021.  Firms were automatically onboarded to relevant TR. 
 
Firms need to connect through the right entry point to either EU or UK TR. Please refer to the FAQ document in the Brexit Technical Document Pack - available now on request. For more information, please contact your Account Manager at UnaVista.

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 Technical Document Pack, which contains latest versions of all available documents will be updated continuously as we progress, is available now on request. For more information, please contact your Account Manager at UnaVista. 


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 Groups & Brexit Updates:

Click here for full details

 

SFTR

We are now in a 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 approach for SFTR trade repositories was that their content was replicated into production UK SFTR TR on the weekend of 1 January 2021, with first UK reports accepted on Monday 4 January 2021.  Firms were 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 FAQ document in the Brexit Technical Document Pack now available on request. For more information, please contact your Account Manager at UnaVista.

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 Technical Document Pack, which contains latest versions of all available documents will be updated continuously as we progress is now available on request. For more information, please contact your Account Manager at UnaVista. 

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 Working Groups & Brexit Updates:

Click here for full details