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Trade reporting 

01 December 2011

Impact Red traffic light

High impact - Significant systems changes likely necessary for sell side, buy side low impact if rely on sell side to do reporting.

Other areas to consider

Transaction reporting

Current MiFID rules

Post-trade transparency

A firm must make public specified information about transactions in shares admitted to trading on a regulated market outside a regulated market or MTF. Typically this must be done within 3 minutes of the transaction taking place. Deferred publication is however permitted for very large trades.

MiFID Level 1 Directive Arts: 14, 27, 28, 29, 30, 44, 45

FSA rules


Proposed changes
Draft Regulation Article 5, Article 6
Article 19(3)(a) and 20 (3)(a)

In response to concerns raised by market participants relating to delays in publication, the Commission is proposing changes to post-trade transparency requirements in equity markets including:

  • specifying that post trade information be published as close to real time as is technically possible;
  • ESMA is to specify in secondary legislation the scope and content of information to be made public and the conditions under which a regulated market, MTF, OTF or SI may provide for deferred publication of trades;
  • shortening the delay permitted under the deferred publication regime for large transactions (e.g. to require all transactions to be published by the end of the trading day (or for very large trades executed late on a day, before opening of business on the next day, to reduce the intra-day delay period to 2 hours, and to raise the intra-day size thresholds)).

The draft Regulation extends the transparency regime to:

  • depositary receipts, exchange traded funds, certificates issued by companies and other similar financial instruments;
  • bonds, structured finance products with a prospectus or admitted to trading on a RM, emission allowances and derivatives that are admitted to trading or that are trading on an MTF or an OTF with the exact requirements to be specified in technical measures;

In addition to requiring further post trade identification of trades on OTFs, there could be identification and flagging of trades that are OTC in post trade transparency reports to help ensure more information is published about the level of OTC trading.

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