As well as reporting, MiFIR stipulates the requirement for firms to implement controls into their businesses to maintain and monitor the accuracy and completeness of their transaction reporting;

“3. Investment firms shall have arrangements in place to ensure that their transaction reports are complete and accurate. Those arrangements shall include testing of their reporting process and regular reconciliation of their front office” (Article 15(3), RTS 22)

Reporting Firms are specifically required to include arrangements to identify;

Ref	Assurance Requirements	Description	Regulatory Requirement
1	Errors	“Mechanisms for identifying errors and omissions within transaction report”	RTS 22 Article 15(1d)
2	Duplications	“Mechanisms to avoid the reporting of duplicate transaction reports”	RTS 22 Article 15(1E)
3	Over-reporting	“Mechanisms to avoid reporting of any transaction where there is no obligation to report”	RTS 22 Article 15(1G)
4	Under-reporting	“Mechanisms for identifying unreported transactions for which there is an obligation to report”	RTS 22 Article 15(1H)
5	Incorrect Position Reporting	“Arrangements in place to ensure that their transaction reports, when viewed collectively, reflect all changes in their position and in the position of their clients”	RTS 22 Article 15(5)
6	Late reporting	“The FCA attaches considerable importance to the timely submission by firms of reports.”	DEPP 6.6

Table 2 – MiFIR transaction reporting assurance requirements

Transaction reporting assurance is setting up and completing these “arrangements”.

Control Now have developed automated solutions to complete this;

TR Accuracy – checks the accuracy of MiFIR and EMIR transaction reports.

TR Completeness – ensure completeness of reporting.