What is Swiss FinfraG Reporting?
The Swiss Financial Market Infrastructure Act (FinMIA), known in German as the Finanzmarktinfrastrukturgesetz (FinfraG), establishes regulatory reporting requirements for Switzerland's financial markets. The framework operates within Switzerland's financial regulatory system overseen by the Swiss Financial Market Supervisory Authority (FINMA).
FinfraG includes distinct reporting requirements for securities transactions under Article 39 and for derivatives transactions. These are broadly comparable to the transaction reporting requirements under MiFID/MiFIR and the derivatives reporting requirements under EMIR respectively.
About Swiss FinfraG Reporting
Swiss FinfraG reporting encompasses two key frameworks: Article 39 transaction reporting and derivatives reporting.
Article 39 covers relevant securities and certain related derivatives, while the separate framework requires those transactions to be reported directly to a trade repository.
Although both can capture the same instruments, they serve different regulatory purposes, with distinct scope, requirements and reporting destinations.
FinfraG Article 39 Transaction Reporting
Article 39 establishes transaction reporting requirements broadly comparable to MiFID/MiFIR transaction reporting.
The reporting obligation covers transactions and order transmissions in relevant securities and certain derivatives linked to those securities. This includes certain equity-based derivatives, whether exchange-traded (ETD) or traded over-the-counter (OTC), where the applicable underlying instrument requirements are met.
Article 39 transaction reports can be submitted to the SIX Swiss Exchange Reporting Office using the applicable Swiss or RTS 22 reporting format. Reports are generally required no later than the end of the trading day following the reportable transaction.
The framework provides Swiss market supervisors with transaction information to support market transparency and regulatory oversight.
FinfraG Derivatives Reporting
FinfraG also establishes a separate derivatives reporting framework, broadly comparable to EMIR reporting.
The regime covers both OTC and exchange-traded derivatives across major asset classes, including credit, commodities, equities, foreign exchange and interest rates, subject to applicable exclusions and exemptions.
Reportable derivatives transactions are submitted to a FINMA-authorised or recognised trade repository. The regime operates on a single-sided basis, with responsibility for reporting determined according to the applicable counterparty hierarchy.
Reportable derivatives transactions are generally subject to T+1 reporting. Modifications and terminations are also reportable following the relevant lifecycle event, while valuation information for outstanding transactions is subject to ongoing reporting requirements where applicable.
Key Features
- FinfraG contains separate transaction and derivatives reporting obligations. Article 39 is broadly comparable to MiFID/MiFIR transaction reporting, while the derivatives reporting framework is broadly comparable to EMIR.
- Article 39 covers transactions and order transmissions in relevant securities and certain derivatives linked to those securities. This can include certain exchange-traded and OTC equity-based derivatives where the applicable underlying instrument requirements are satisfied.
- Article 39 transaction reports can be submitted to the SIX Swiss Exchange Reporting Office and are generally required no later than the end of the trading day following the reportable transaction.
- FinfraG derivatives reporting covers both OTC and exchange-traded derivatives across major asset classes, including credit, commodities, equities, foreign exchange and interest rates, subject to applicable exclusions and exemptions.
- FinfraG derivatives reports are submitted to a FINMA-authorised or recognised trade repository and reportable transactions are generally subject to T+1 reporting.
- FinfraG derivatives reporting operates on a single-sided basis, with responsibility for reporting determined according to the applicable counterparty hierarchy.
- Lifecycle and valuation information is also subject to reporting requirements. Modifications and terminations are reportable following the relevant lifecycle event, while valuations for outstanding derivatives are subject to ongoing reporting requirements where applicable.
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FAQs: Swiss FinFraG Reporting
FinfraG establishes regulatory reporting requirements for Switzerland's financial markets. These include Article 39 transaction reporting for relevant securities and certain related derivatives, as well as a separate derivatives reporting framework.
Article 39 is broadly comparable to MiFID/MiFIR transaction reporting. It requires the reporting of transactions and order transmissions in relevant securities and certain derivatives linked to those securities, including certain exchange-traded and OTC equity-based derivatives where the applicable requirements are met.
Article 39 reporting applies to participants subject to the relevant Swiss transaction reporting requirements, including participants admitted to Swiss trading venues. Whether a particular firm is required to report depends on its status and activities under the applicable Swiss rules.
Article 39 transaction reports can be submitted to the SIX Swiss Exchange Reporting Office using the applicable Swiss or RTS 22 reporting format.
Article 39 transaction reports are generally required no later than the end of the trading day following the reportable transaction.
FinfraG derivatives reporting is a separate reporting obligation broadly comparable to EMIR. It requires information on reportable derivatives transactions to be submitted to a FINMA-authorised or recognised trade repository.
The reporting obligation depends on the status of the counterparties and the applicable reporting hierarchy. FinFraG operates a single-sided derivatives reporting model, meaning the rules determine which counterparty is responsible for reporting the transaction.
Both OTC and exchange-traded derivatives may be reportable. The regime covers derivatives across major asset classes, including credit, commodities, equities, foreign exchange and interest rates, subject to applicable exclusions and exemptions.
Reportable derivatives transactions are submitted to a FINMA-authorised or recognised trade repository.
Reportable derivatives transactions are generally subject to T+1 reporting. Modifications and terminations are also reportable following the relevant lifecycle event.
FinfraG derivatives reporting operates on a single-sided basis. The counterparty responsible for reporting is determined according to the applicable reporting hierarchy.
Free FinfraG Reporting Tools
External FinfraG Resources
- Circular 2018/2: Duty to Report Securities Transactions | FINMA
- Trade & Transaction Reporting | SIX Swiss Exchange
- Legal Basis for Financial Market Infrastructures and Markets | FINMA
- Financial Market Infrastructure Act (FinMIA/FinFraG)
- Swiss Financial Market Infrastructures | FINMA
- FinFraG Derivatives Reporting | SIX Trade Repository