ESMA updates MiFIR validation rules (Q2 2022)
October 20, 2021
ESMA have published a new version (1.6) of MIFIR Validation Rules document.
The changes include: 6 new validation rules, updated 14 existing validation rules and updated error text for one of the existing validations.
The changes will be applicable from Q2 2022, however the exact implementation date has not been communicated yet.
Update 28/03/2022:
Today ESMA have communicated the go-live for the 1.6 version of changes to be 31/05/2022.
At the same time ESMA have publised version 1.7 of changes, further clarifying rules 027, 043, 056, 072 previously changed by v.1.6.
Update 11/04/2022:
We have received an update from FCA on implementation of the changes published by ESMA.
FCA decided to not enforce the changed/new rules. They are however happy for firms to “implement these additional and other validations should they wish to, where they feel this will improve the data quality of their submissions”.
Update 31/05/2022:
Between 03/12/2021 and 31/05/2022 Control Now have been executing these validations as a part of the TR Accuracy offering to allow clients to prepare for upcoming changes. All validations are named after the Rule ID (e.g. for Rule ID 041 – CN validation is MT041). Please see 03/12 Release Notes (item 12).
As of 01/06/2022 these validations have been included in the MiFIR Core Validations module and removed from TR Accuracy to avoid duplication. Please see 31/05 Release notes.
Change type | Rule ID | Error code | Affected field(s) | Rule Description |
New | 041 | CON-110 | Buyer – date of birth (11) | Date of birth for affected fields should not be later than trading date. |
053 | CON-150 | Buy decision maker – Date of birth (15) | ||
070 | CON-200 | Seller – date of birth (20) | ||
082 | CON-240 | Sell decision maker – date of birth (24) | ||
Changed | 027 | CON-070 | Buyer identification code (7) | Included clarification that the ‘EntityStatus’ of LEI reported in affected fields shall be ‘Active’ on the trading date. |
043 | CON-120 | Buyer decision maker code (12) | ||
056 | CON-160 | Seller identification code (16) | ||
072 | CON-210 | Seller decision maker code (21) | ||
Changed | 111 | CON-350 | Net Amount (35) | Field ‘Net Amount’ is made mandatory for additional groups of products (previously only DB**** (Bonds)). Added products CFI codes: DC**** (convertible bonds), DT**** (medium term notes) and DN**** (municipal bonds). See Control Now TR Accuracy MI: ‘Bonds Pricing MI’ |
262 | CON-351 | |||
Changed | 270 | CON-361 | Venue (36) | Added clarification that for population of ‘XXXX’ in ‘Venue’ field. If ‘Instrument Identification Code’ is provided, then it must not be present in reference data for the relevant trade date. |
New | 283 | CON-362 | Clarified that transactions executed directly on venues cannot be transmitted (when ‘Transmission of order indicator’ is ‘true’, the ‘Venue’ field should be XOFF or XXXX). See Control Now TR Accuracy MI: Transmission of order indicator. |
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Changed | 117 | CON-370 | Country of the branch membership (37) | Clarified that field ‘Country of the branch membership’ should not be optional for SIs. |
New | 284 | CON-372 | Clarified that field ‘Country of the branch membership’ must be blank for SIs, XOFF and XXXX. | |
Changed | 220 | CON-412 | Instrument identification code | The error text is amended to include also MIC identification. The validation rule itself is not changed. |
Changed | 140 | CON-452 | Notional currency 2 (45) | Field is now mandatory for wider range of currency products (previously only currency swaps (SF****) and currency futures (FFC***)). Added products: currency forwards (JF****), warrants on currencies (RWC***), mini-future certificates/constant leverage certificates on currencies (RFC***), Structured instruments without capital protection on currencies (DE***C) and Structured instruments – capital protection on currencies (DS***C). |
Changed | 250 | CON-453 | Notional currency 2 (45) | Field must be blank for wider range of products: non-currency products from groups: entitlements, debts, forwards (RA****, RS****, RP****, RD****, RM****, RX****, RWB***, RWS***, RWD***, RWT***, RWI***, RWM***, RWX***, RFB***, RFS***, RFD***, RFT***, RFI***, RFM***, RFX***, DB****, DC****, DW****, DT****, DG****, DA****, DN****, DD****, DM****, DY****, DX****, DE***B, DE***S, DE***D, DE***T, DE***I, DE***N, DE***M, DE***X, DS***B, DS***S, DS***D, DS***T, DS***I, DS***N, DS***M, DS***X, JE****, JC****, JR****, JT****, JX****). |
Changed | 154 | CON-480 | Underlying index name (48) | Field is now also mandatory for index based mini-future certificates/constant leverage certificates (RFI***). Added to index based options (O**I**, O**N**), futures (FFI**, FFN***) and entitlements (RWI***). |
264 | CON-481 | Field must be blank for wider range of equity products and collective investment vehicles (previously only chosen debt products (DB****, DT****, DY****)). Added products: ES****, EP****, EC****, EF****, EL****, ED****, EM****, EX**** and C****. |
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Changed | 166 | CON-530 | Option exercise style (53) | Field is now also mandatory for Mini-future certificates/constant leverage certificates (RF****). Previously only options (O***** and H*****) and warrants (RW****). |
Changed | 228 | CON-571 | Investment decision within firm (57) | Included clarification for cases when fields ‘Buyer decision maker code’ and ‘Seller decision maker code’ are left blank. |
https://www.esma.europa.eu/document/transaction-reporting-validation-rules-2021-update
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