MiFID Price & Quantity Notation: Prevent Market Watch 74 Silent Errors
Key Takeaways
- Incorrect price and quantity notation can create “silent errors” in MiFID reporting, where submissions pass validation but still contain inaccurate data.
- FCA MarketWatch 74 highlights these issues as a key data quality concern, particularly where firms misinterpret reporting fields.
- These errors can lead to regulatory scrutiny and costly remediation despite reports appearing technically valid.
- Firms need stronger validation, controls, and reconciliation processes to detect and prevent silent errors before submission.
- Improving data quality at source is critical to ensuring accurate, audit-ready transaction reporting.
MarketWatch 74 highlights how inconsistent price and quantity notation can create silent MiFID reporting errors, even when reports pass validation.
Learn best-practice notation choices, where mismatches happen (monetary vs percentage vs bps; units vs nominal), and the controls that prevent mis-reporting.
Market convention matters in MiFID reporting: the wrong price or quantity notation can turn a valid-looking report into a silent error. Use controls that validate notation by instrument, trade structure, and counterparty consistency.
In MarketWatch 74, released by the FCA in July 2023, the regulators encourage firms to adopt market conventions when specifying Price and Quantity notations within their MiFID transaction reports.
Industry Best Practices
Consistency in reporting Price and Quantity enables the regulators to conduct regulatory supervision more efficiently. In MiFID reporting, a Price specified as a Monetary value is vastly different from a Price specified as a Percentage value. This is precisely why regulators are encouraging market participants to adopt industry Best Practices when specifying Price and Quantity.
In MarketWatch 74, the FCA noted:
"In cases other than where a specific price or quantity type is required for the instrument traded (for example, credit default swaps (CDS) - price in basis points; equity - quantity in units), firms may determine the most appropriate notations to report. We urge firms to follow market convention when determining which notation to use. Where possible, firms should ensure that the notations selected are consistent with those reported by their counterparties. We have identified cases of the same transaction being reported using different price or quantity notations by firms facing one another. For example, one side using a monetary price and the other using a basis point price."
Market Watch 74 also reminds firms of the need to ensure that the reporting of price and quantity notations aligns not only with the instruments but also with the structure of the trade. For example, in complex trades where a simultaneous buy and sell of two or more instruments occurs, the trade is typically quoted at a single price, usually a spread in basis points, rather than reporting individual prices and price types for each leg. Firms should ensure their transaction reporting reflects this approach to remain compliant with the guidelines.
Qomply's solutions incorporate the Best Practices from across trade bodies and associations. This means that Price and Quantity notations are flagged if the notation deviates from market convention or Best Practices for that particular asset or product type.
How Qomply can help
Qomply’s Regulatory Reporting Hub combines regulatory expertise with AI, automation and data analytics to deliver scalable, audit-ready reporting intelligence that reduces errors, lowers remediation costs, and minimises operational and regulatory risk.
Covering regimes including MiFIR, EMIR Refit, SFTR, CFTC, CSA, MAS, ASIC and HKMA, Qomply also offers a fully managed service and operates globally from London.
Frequently asked questions
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It says silent errors arise because reports can pass validation while still using the wrong notation for the instrument or trade structure. The article emphasises that a monetary price, percentage price, and basis-point price are not interchangeable.
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It urges firms to follow market convention when deciding which notation to use. The article also says firms should try to align notation with the way their counterparties report the same transaction.
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It says mismatches commonly occur between monetary, percentage, and basis-point price conventions and between unit and nominal quantity conventions. The article presents these as practical areas where firms can report a trade in a valid-looking but wrong way.
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It says complex trades should reflect the structure of the trade, not just the instrument. The article gives the example of simultaneous buy and sell trades being quoted as a single spread in basis points rather than separate leg prices.
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They should apply controls that validate notation by instrument, trade structure, and counterparty consistency. The article says firms need notation checks based on market convention, not just basic validation-pass logic.