Transaction reporting under MiFIR Article 26 remains one of the most error-prone regulatory obligations for investment firms. This pack gives you the field-level mapping, validation logic, and quality assurance framework to get your reporting right — and keep it right.
With AFM increasingly using transaction report data for market abuse detection and best execution supervision, data quality isn't just a compliance checkbox — it directly affects your supervisory risk profile.
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MiFIR Article 26 requires investment firms to report complete and accurate details of transactions in financial instruments to their National Competent Authority — in the Netherlands, that's AFM. The reporting regime covers 65 fields per transaction, spanning instrument identification, client and counterparty data, execution details, and trader identification.
Despite being in force since 2018, transaction reporting remains a persistent pain point. AFM regularly identifies data quality issues during supervisory reviews, and ESMA's peer reviews consistently highlight reporting accuracy as a cross-border concern. This pack addresses the root causes: unclear field mapping, inconsistent reference data, and the absence of systematic quality assurance.
Complete mapping of all 65 reporting fields to internal data sources. Covers equities, bonds, derivatives, and structured products with field-level guidance on data sourcing, formatting rules, and conditional reporting logic per instrument type.
Practical guide to instrument identification under FIRDS and ANNA-DSB. Covers ISIN sourcing, CFI codes, UPI for OTC derivatives, and the reference data challenges that cause the majority of reporting rejections.
Decision framework for selecting an Approved Reporting Mechanism. Compares major ARMs across connectivity options, validation strictness, error handling, and pricing. Includes technical setup checklists for FIX, SFTP, and API connectivity.
Comprehensive pre-submission validation rule set covering format checks, cross-field consistency, reference data lookups, and business logic validations. Designed to catch errors before they reach your ARM and generate rejections.
Procedures for handling rejections, cancellations, and amendments. Includes error classification, root cause analysis templates, correction workflows, and the documentation requirements for demonstrating remediation to AFM.
Periodic quality assurance framework covering completeness checks, accuracy sampling, timeliness monitoring, and trend analysis. Includes dashboard templates for management reporting and the documentation AFM expects during reviews.
This pack is for investment firms that execute transactions in financial instruments and are therefore subject to MiFIR transaction reporting obligations. It's particularly valuable for firms that self-report (rather than relying entirely on their execution venue), firms experiencing high rejection rates, and compliance teams preparing for AFM data quality reviews.
The pack focuses on direct reporting via an ARM, which is the most common approach for Dutch investment firms. However, the field mapping and validation rules are equally relevant for firms that verify the accuracy of reports submitted by their execution venue on their behalf.
Yes. Even firms that execute exclusively on regulated markets or MTFs have reporting obligations for certain transaction types (e.g., give-ups, allocations, and certain portfolio management transactions). The pack covers these scenarios specifically.
Yes. The field mapping includes detailed guidance on NCI determination for natural persons (CONCAT algorithm) and legal entities (LEI), including the Dutch-specific implementation details and the common pitfalls with cross-border client identification.
They're complementary. MiFIR covers transaction reporting to AFM; EMIR covers trade reporting to Trade Repositories. Many firms have both obligations for derivative transactions. The packs are designed to work together, with consistent field mapping approaches and shared reference data guidance.