Transaction reporting

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:

  1. 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;
  2. financial instruments where the underlying is a financial instrument traded on a trading venue;
  3. financial instruments where the underlying is an index or a basket composed of financial instruments traded on a trading venue.

What should be reported?

Regulations and guidelines Information to be reported Reporting frequency and reference dates Submission dates
2/2018 Kaupparaportointi, tarjouskirjanpito ja kellotahdistus MiFID II:n mukaisesti (in Finnish)

Transactions executed on financial instruments

 

 

Without delay or the next day

 

When are transactions reported?

Report transactions to the FIN-FSA at the latest on the working day following the transaction date.

  1. The reporter registers for the SFTP service using a form that includes, among other things, the public key of the SSH key pair you generate.
  2. The Finnish Financial Supervisory Authority (FIN-FSA) sends the SFTP credentials and passwords to the reporter via secure email.
  3. Submit the transaction report as a file using the SFTP connection.

   SFTP Connection Guide

  Technical reporting instructions (information about naming conventions etc.).

Test transaction reporting before beginning production reporting. You register to the test service in the same way as to the production service.

Both parties to a transaction, where they are investment service providers, report for themselves. However, the following information in both reports must match: venue, transaction time, volume, price, currency, up-front payment, currency of up-front payment and details of the financial instrument.

The overall view provided by the transaction reports must describe the changes in the reporter’s position or its client’s position due to the transaction. The reports must also indicate the roles of the reporter, the counterparty, any clients, and those acting on behalf of clients by proxy.

Transmitted orders shall be reported or arrangements shall be made for reporting them by the receiving investment service provider.

A transaction shall be reported on several reports if required by the type of transaction. The same transaction may call for several transaction reports for example if an executed transaction is allocated to several clients.

Changes and topical matters concerning transaction reporting are communicated in the Markets in financial instruments (MiFID II and MiFIR) newsletters (available only in Finnish).

The most recent newsletters can be found on the Newsletters and further information sheet for the MiFID II and MiFIR regulatory framework.

You can subscribe to the newsletter by completing the registration form.

Notifications of errors or omissions in transaction reporting are made in FIN-FSA e-services. 

According to Article 15(2) of Commission Delegated Regulation (EU) 2017/590 (RTS 22), investment firms must notify the FIN-FSA of any errors or omissions they become aware of in transaction reporting.

Use of e-services requires strong identification of the user. Users must identify themselves using the Suomi.fi service. Users notifying errors or omissions in transaction reporting must have a transaction reporting authorisation in order to send transaction reporting error notifications on behalf of a firm. A transaction reporting error notification form can be found in the investment services section of FIN-FSA e-services.