MiFIR RTS 22 Transaction Reporting Updates & Timeline (2024-2026)

The European Securities and Markets Authority (ESMA) is progressing with its comprehensive review of MiFID II and MiFIR, introducing significant updates to the MiFIR Regulatory Technical Standards (RTS) 22 framework for transaction reporting. This review, a critical part of ESMA’s commitment to enhancing regulatory efficiency and data quality, is designed to align reporting obligations with evolving market practices and other financial regulations such as EMIR Refit and MiCA.

Following the release of a Consultation Paper (CP) on 3 October 2024, ESMA has set a timeline for industry feedback by the 3^rd of January 2025. The issuance of the Final Report of the RTS update is expected to be in Q1 of 2025. Firms should prepare for the go-live of MiFIR RTS 22 changes, expected in Q1 2026, by understanding the proposed revisions and their potential impacts.

Key Changes to MiFIR RTS 22

1. Scope of Reporting

ESMA proposes expanding the scope of products subject to MiFIR RTS 22 reporting. Key updates include:

• Crypto-Asset Derivatives: As the Markets in Crypto-Assets (MiCA) regulation progresses, crypto products traded on trading venues will fall within RTS 22’s reporting requirements. This aligns MiFIR with emerging regulatory standards for digital assets.

2. Alignment with Other Regulations

The revisions aim to harmonise MiFIR reporting with EMIR Refit and SFTR, ensuring consistency in field definitions and data standards. This alignment addresses long-standing industry concerns over discrepancies between overlapping regulatory requirements.

3. Field Adjustments

The CP outlines several changes to transaction reporting fields, including the addition of new fields, updates to existing ones, and the removal of outdated elements.

• New Fields:
  • • • Effective Date/Reporting Timestamps: Harmonises reporting timelines with EMIR Refit.
      • Trading Venue Transaction Identification Code (TVTIC): Introduced for transactions on non-EEA venues.
      • Token Identifiers: Prepares for digital asset reporting under MiCA.
      • Aggregated Order Identifiers: Adds fields to identify chains of aggregated orders, akin to EMIR’s Package Identifier Code.
      • Client Identifiers: Enhances clarity around counterparties, particularly non-entity clients.
• Amendments to Existing Fields: Minor adjustments to fields such as Net Amount, Buyer/Seller, and Executing Entity are proposed to improve consistency with other frameworks. New values will be introduced while maintaining compatibility with existing reporting formats.
• Removed Fields:
  • • • The Short Selling Indicator is slated for removal, as it is deemed redundant.