Changes to MIFIR RTS 22 Transaction Reporting

In Q4, ESMA and the FCA released papers with proposals of changes to MIFIR RTS 22 transaction reporting. The proposals set up for expected go-lives of updates standards some time in 2026. Exact dates and final details are pending reviews by ESMA and the FCA of feedback to their consultation papers and the release of final standards. ESMA may potentially release their final draft of RTS 22 changes at the end of Q1 2025 with the FCA to follow afterwards.

While we don’t have final details yet, a few trends emerged from the proposals of the direction ESMA and the FCA are moving towards to improve quality of the RTS 22 reports.

Scope: Reportable products under scope primarily remains the same and will continue to cover securities trading on a trading venue (TOTV) and underlying trading on a trading venue (UTOTV) with ESMA introducing a requirement to report certain OTC Interest Rate and Credit derivatives that are cleared.

Allocations and Fills: Both ESMA and the FCA raised proposed changes to how firms report trades with subsequent allocations and the use of the INTC value. The update would be focused on providing more granular information of linking fills and allocations.

Harmonization: Following the lead of global derivative regulation changes, RTS 22 proposals included the introduction of new fields that exist in EMIR and SFTR along with expanding the list of allowable values of various existing fields to align with values that are used under EMIR and SFTR.

Clarity: In their discussion paper, the FCA listed a number of fields where they explained existing definitions might be unclear. The FCA stated that they aim to provide additional clarity with enhanced definitions of fields and conditions when they are relevant to different trading firms and transaction scenarios.

Field Removal: Both ESMA and the FCA included in their proposal the removal of certain fields that are providing little value to the regulators.

EU and UK Divergence: Another trend that is worth mentioning on its own is the diversion between the EU and UK standards of RTS 22. Although some proposals are aligned, there were a number of items that the UK included differing proposals from ESMA. This included differences in the fields being removed, introduction of new fields and inclusion of new products under scope. While the overall reporting framework remains similar, if the final drafts are similar to the proposals, RTS 22 under MIFIR will mark the first major diversion of transaction reporting regulation since Brexit took place.