In accordance with Article 26 of the Markets in Financial Instruments Regulation, complete and accurate details of transactions in financial instruments shall be reported to the competent authority.
Who is subject to the transaction reporting obligation?
Transaction reporting applies to
- investment service providers executing transactions in financial instruments
- investment service providers receiving orders and transmitting orders for execution to other investment service providers
- operators of a trading venue, where its systems are used to execute transactions of a firm which is not subject to MiFIR
- approved reporting mechanisms (ARM).
For the purposes of transaction reporting, investment service providers refer to investment firms authorised under Directive 2014/65/EU (MiFID II) and credit institutions authorised under Directive 2013/35/EU of the European Parliament and of the Council when providing investment services and/or performing investment activities and to market operators including any trading venues they operate.
Financial instruments subject to reporting are defined in Article 26 (2) of MiFIR. According to the definition, financial instruments subject to reporting are:
- financial instruments which are admitted to trading or traded on a trading venue or for which a request for admission to trading has been made;
- financial instruments where the underlying is a financial instrument traded on a trading venue;
- financial instruments where the underlying is an index or a basket composed of financial instruments traded on a trading venue.
When are transactions reported?
Report transactions to the FIN-FSA at the latest on the working day following the transaction date.
- Register to the reporting service: https://dcs.bof.fi
- Wait for FIN-FSA approval and list of single-use passwords.
- Submit the transaction report on a form, in a file in the reporting service or via SFTP connection.
Test transaction reporting before beginning production reporting. You register to the test service in the same way as to the production service. The test reporting service is available at https://test.dcs.bof.fi.
Report the transaction in several reports if required by the type of trading. The same transaction may call for several transaction reports, for example if an executed transaction is allocated to several clients. Report transmitted orders yourself or make arrangements for their reporting by the receiving investment service provider.
The overall view provided by the transaction reports must reflect the changes in your position or your client's position due to the transaction. Your reports must also reflect the roles of yourself, your counterparty, your clients and the parties acting for clients under a power of representation.
Where both parties to a transaction are investment service providers, they report for themselves. However, the following elements in both reports must match: venue, transaction time, quantity, quantity currency, price, price currency, up-front payment, currency of up-front payment and details of the financial instrument, where necessary.
- Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012 Text with EEA relevance
- Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities
- Määräykset ja ohjeet 2/2018 Kaupparaportointi, tarjouskirjanpito ja kellotahdistus MiFID II:n mukaisesti (in Finnish)