Guides

T+1 Trouble? A MiFID Checklist for US Firms Trading OTC Products in UK & Europe

Published:12th August 2025

Helps US firms trading OTC products in the UK and Europe determine whether they are in scope for MiFID II transaction reporting.
Explains key challenges in meeting T+1 reporting deadlines and identifying reportable instruments via FIRDS.
Outlines operational requirements including XML reporting, data fields, and approved reporting mechanisms (ARMs).
Highlights the importance of reconciliation, validation, and demonstrating reasonable assurance over reported data.
Designed for compliance and operations teams managing cross-border MiFID II reporting obligations.

Qomply’s T+1 Trouble? A MiFID II Checklist for US Firms Trading OTC Products in the UK & Europe guide helps US firms understand whether they are in scope for MiFID II transaction reporting and how to meet their obligations effectively. It breaks down the complexity of cross-border reporting requirements, particularly for firms trading OTC products or interacting with UK and EU venues.

The guide outlines seven key questions firms should consider, including whether their activities trigger reporting obligations, how execution pathways impact responsibility, and how to determine instrument reportability using FIRDS. It also explores the challenges of meeting T+1 deadlines, especially for US-based teams operating across time zones.

In addition, it highlights the importance of robust internal systems capable of generating XML reports with 65+ mandatory fields, as well as the need for approved reporting mechanisms (ARMs) and reliable submission pathways. The guide also emphasises reconciliation, data validation, and the requirement to demonstrate reasonable assurance over reporting accuracy.

Finally, it addresses governance and remediation, explaining how firms should handle reporting errors, maintain audit trails, and implement structured error and omissions frameworks to meet regulatory expectations. Designed for compliance and operations teams, this guide provides a practical framework to reduce risk, avoid regulatory scrutiny, and strengthen reporting processes.

Qomply helps financial firms achieve accurate, compliant transaction reporting across global regulatory regimes, while streamlining the operational and audit demands of regulatory reporting.

Our proprietary technology combines AI, automation and advanced data analytics to deliver scalable, audit-ready reporting intelligence. Through forensic-level quality assurance and streamlined reconciliation, Qomply helps firms strengthen data quality and reporting accuracy, automate controls, simplify audit processes and lower overall reporting costs.

Our technology provides greater oversight and operational efficiency while reducing the demands on internal teams.

For firms seeking to outsource their regulatory reporting operations, Qomply also offers a fully managed service. Combining our technology with deep regulatory expertise, Qomply Managed Services operates as an extension of, or alternative to, an in-house reporting function. This flexible model enables firms to outsource reporting operations while retaining the option to bring activities in-house as their own capabilities and resources evolve.

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