ESMA MiFIR Review: Key Proposals & Dates
Key Takeaways
- Scope Expansion: ESMA's consultation proposes extending RTS 22 reporting into additional OTC derivatives, particularly where clearing-obligation and major-currency conditions apply.
- Field Architecture Shift: New fields for effective dates, aggregation links, and reporting-obligation entities indicate a more granular MiFIR data model.
- Standards Alignment: The review seeks greater harmonisation between MiFIR, EMIR Refit, and global reporting frameworks, signalling continued convergence in regulatory data design.
ESMA's fourth MiFIR Review consultation focuses on amended RTS 22 transaction reporting requirements. Key changes include expanded transaction reporting scope for certain OTC derivatives, new reporting fields and identifiers, and greater alignment with EMIR Refit and global reporting standards.
ESMA has issued its fourth consultation package under the MiFIR Review, with a specific focus on amended RTS 22. This is a critical step in firms preparing for changes in reporting.
Key Proposals Include:
- Expanded Transaction Reporting Scope: As noted in amended Article 26 of MiFIR, the consultation proposes new rules for reporting OTC derivatives transactions, including those denominated in major currencies (EUR, USD, JPY, GBP) and subject to the clearing obligation.
- New Reporting Fields & Identifiers: Introduction of fields to capture the effective date of transactions, new identifiers for linking aggregated orders, and requirements for the reporting obligation entity.
- Alignment with International Standards: Field adjustments to harmonise MiFIR reporting with EMIR REFIT and global reporting frameworks, streamlining regulatory processes across jurisdictions.
Key Dates:
- Consultation deadline: 3 January 2025
- ESMA submission to the European Commission: Q1 2025
- Final standards expected: 29 September 2025
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Frequently asked questions
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It focuses on amended RTS 22 transaction reporting requirements. The article says the consultation is especially important for firms preparing for changes in MiFIR reporting scope, fields, and identifiers.
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It highlights proposed scope expansion for certain OTC derivatives, including those denominated in EUR, USD, JPY, and GBP and subject to the clearing obligation. The article presents this as one of the headline changes in amended Article 26.
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It says ESMA is proposing fields for the effective date of transactions, new identifiers for linking aggregated orders, and fields for the reporting-obligation entity. The article groups these as core structural additions to the regime.
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It says field adjustments are being proposed to align MiFIR reporting more closely with EMIR Refit and global reporting standards. The article frames that as part of a wider harmonisation effort across regimes.
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It gives 3 January 2025 as the consultation deadline, Q1 2025 for ESMA's submission to the European Commission, and 29 September 2025 as the expected timing for final standards. The article says firms should engage early because consultations are a strategic opportunity as well as a compliance matter.
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