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29 October 2015 | Regulatory services

How much overlap is there between the EMIR and MiFIR reportable fields? Comparing EMIR and MiFIR reportable fields

Many organisations will be reviewing the available data they already have captured for previous regulations such as MiFID and EMIR with a view to reusing it to satisfy the requirements of MiFIR. So a key question is, where are their similarities and where are their differences? Certainly, there are a number of categories the fields fall into:

  • Fields that are the same – there are some fields that are fundamentally the same regardless of regulation, for example key dates such as execution, ISO standards such as currency or country.
  • Fields that are unique to MiFIR – there are a number of fields that are introduced in MiFIR that will not have previously been captured for MiFID or EMIR. Examples include information about who made the investment decision versus performed the actual execution, and similar data from an algorithmic perspective.
  • Finally, fields that are similar, but not quite the same – this is the area that has the most potential to trip firms up since it will be tempting to use existing data that is valid most of the time, thankfully they are relatively few in number. Examples here are Counterparty Identifiers and Instrument Identifiers where the allowable values in MiFIR are restricted compared to allowable values in EMIR.

In summary, organisations should evaluate carefully the data they are already capturing for regulatory reporting and identify the gaps in data attributes and transaction coverage so that they can enhance the data set for MiFIR.

Look out for a detailed walkthrough of the MiFIR data attributes in a forthcoming article from Deutsche Börse Group.

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