MiFIR transparency: who holds the responsibility to report?

The framework for deciding who holds the responsibility to submit MiFIR post-trade transparency reports is being modified in the UK and the EU.

Under changes introduced within the UK’s Wholesale Markets Review and the EU’s MiFIR Review, the MiFIR post-trade transparency framework is set to change the reporting rules defining who reports a trade in a financial instrument. In the UK, the Designated Reporter (DR) regime will be introduced on 29 April 2024, while in the EU the Designated Publishing Entity (DPE) regime will be introduced later in 2025.

Benefits of the new reporting frameworks

In both regimes, the new frameworks are set to clarify that firms who are registered as a DR/DPE hold the responsibility to fulfil Post-Trade Transparency (PTT) requirements. This will provide greater simplicity and clarity to regulatory reporting, alongside improvements to the data quality of reported transactions. “We welcome the new reporting frameworks which will resolve longstanding complexities with the post-trade transparency regimes in both the EU and UK,”, commented Sean Barwick, Director, Regulatory and Public Affairs at BNP Paribas Global Markets.

We welcome the new reporting frameworks which will resolve longstanding complexities with the post-trade transparency regimes in both the EU and UK,

Sean Barwick, Director, Regulatory and Public Affairs,
BNP Paribas Global Markets

A new framework to determine reporting entities

The logic to determine which counterparty is responsible to submit a report will remain the same. However, where previously Systematic Internaliser (SI) status acted as the key determinant, in the new framework this will be replaced by DR/DPE status:

  • DRs will be responsible for submitting PTT reports when transacting with a counterparty who is not a DR/DPE
  • If two DR/DPEs trade with each other, the seller will hold the responsibility for submitting a PTT report
  • If neither counterparty is a DR, the selling firm will hold the responsibility for submitting a PTT report

Who can register as a DR/DPE?

Any investment firm can register to become a DR/DPE regardless of their SI status. In the UK, the FCA will maintain a list of registered DRs which is made available on the FCA’s website. In the EU, ESMA will maintain a similar register on its website for DPEs. “BNP Paribas will register as a both a DR and a DPE. Accordingly, the bank will continue to take responsibility for MiFIR post-trade transparency reporting for clients in all cases, except where clients are a DR or DPE themselves,” said Quentin van Lidth, Director, Regulatory and Public Affairs, BNP Paribas Global Markets.

BNP Paribas will register as a both a DR and a DPE. Accordingly, the bank will continue to take responsibility for MiFIR post-trade transparency reporting for clients in all cases, except where clients are a DR or DPE themselves,

Quentin van Lidth, Director, Regulatory and Public Affairs,
BNP Paribas Global Markets

More on this topic

For further information please take a look at BNP Paribas’ factsheet on the DR/DPE regimes. If you have any comments or questions, please contact the BNP Paribas EMEA Regulatory team or your usual BNP Paribas representative.

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