MiFID Field 28: Trading Date/Time for Corporate Actions and Corporate Events
Key Takeaways
- Event-Time Principle: Field 28 should capture the time the corporate action was completed by the initiating entity, not the later execution time of resulting trades.
- Common Misreporting Pattern: Midnight timestamps, rounded hours, and execution-time substitution are identified as recurring errors in corporate-action reporting practice operationally.
- Process-Integration Weakness: Corporate events are often handled in back-office functions, increasing the risk that required timing data never reaches reporting systems.
- Training Requirement: Firms need staff understanding of the exact regulatory timestamp required, rather than relying on default trade-processing conventions operationally.
- Issuer-Confirmation Relevance: In many cases, the correct Field 28 time may align more closely with issuer confirmation than with trade execution activity.
MiFID Field 28 (Trading Date Time) for corporate actions should reflect the timestamp when the corporate event was completed by the initiating entity. This guide explains common misreporting patterns (midnight timestamps, rounded times, and using trade execution time) and practical steps firms use to capture and report the correct corporate action completion time.
Across the industry, there appears to be confusion over which date and time to report for transactions initiated and executed as part of a corporate event.
Many firms are not capturing and reporting the time of the completion of the corporate action by the initiating entity.
In many instances, firms are using the execution date and time of the transactions associated with a corporate action. Or, if they do capture the correct date, firms are either specifying midnight or rounding-up the time by padding the minutes and seconds fields with 00:00.
Instead, there appears to be three common mistakes when reporting Field 28 Trading Date Time of the MiFID Transaction report in regard to corporate actions:
1) The time of the completion of the corporate action is denoted as midnight and Field 28 contains 2021-03-01T00:00:00.000000Z
2) The time is rounded-up to the nearest hour, 2021-03-01T10:00:00.000000Z
3) The date and time are noted as the execution time of the transactions resulting from a corporate action as opposed to the completion of the corporate action, itself.
It appears firms struggle with determining what constitutes the actual time of a corporate action and how to effectively capture and transmit that information to the systems producing the transaction reports.
According to ESMA, the expected Trading Date Time "would be the date and time that the corporate action was completed by the entity initiating the event.
Since most financial institutions deal with corporate events as a back-office function with limited front office interaction, essential information may not be transmitted and/or captured properly by the Front Office Systems. Also, in some cases, there may be a lack of understating of the MiFID requirement to capture the exact time of the completion of the corporate action as opposed to the time the associated transactions were executed. Therefore, when trades are executed, they simply fall through the same reporting framework as other trades and the Trade Date and Time are erroneously reported.
Therefore, firms should ensure their staff are adequately trained to capture and record the specific time of the completion of the corporate action and, in many cases, this may be the date and time of the confirmation of the transaction by the issuer as opposed to the execution of the associated trades.
ESMA clarifies these points in their Q&A on MiFID Transaction Reporting.
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Frequently asked questions
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It should show the timestamp when the corporate action was completed by the entity initiating the event. The article says firms often report the wrong time because they use associated trade execution times instead.
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It identifies three common mistakes: reporting midnight, rounding the time up to the nearest hour, and using the execution time of the resulting trades instead of the completion time of the corporate action. The article says these are widespread misreporting patterns.
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It says firms struggle because corporate events are often treated as a back-office function and the critical completion time is not properly captured or transmitted into front-office reporting systems. The article also says some firms do not understand that MiFID wants the exact completion time of the corporate action itself.
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ESMA expects the date and time when the corporate action was completed by the entity initiating the event. The article links this directly to ESMA's MiFID transaction-reporting Q&A.
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They should train staff to capture and record the actual completion time of the corporate action and make sure that timestamp is passed into the reporting chain. The article says that time may often be the issuer's confirmation time rather than the execution time of the related trades.
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