MiFIR Review prompts compliance platforms to shift gears

Key Takeaway

• MiFIR Review addresses areas including post-trade transparency and transaction reporting.  

• As updated rules aim for more efficiency and simplified reporting, firms need to ensure their toolkits are MiFIR Review compliant.  

• Platforms with built-in surveillance and flexible update capabilities help adjust. 

As reporting rules undergo major upgrades, firms across different jurisdictions need the right capabilities to ensure trades are processed and reported according to the new criteria.

The implementation of the Markets in Financial Instruments Regulation (MiFIR) Review highlights this need.

The MiFIR Review introduces, among others, significant updates across three main areas: post-trade transparency for investment firms, transaction reporting for Investment firms, and post-trade transparency for trading venues. While some changes are already in effect, other amendments remain under consultation, requiring firms to stay adaptable. As the overarching goal is to enhance market transparency, improve data quality, and align reporting across jurisdictions, full implementation will continue in stages.

Most MiFIR amendments came into force on 28 March 2024, with further changes –dependent on delegated acts – phasing in through 2025 and 2026. The updates of the accompanying Markets in Financial Instruments Directive (MiFID II) must be transposed into national law by 29 September 2025, with full implementation expected by the end of 2026.

The MiFIR Review, along with related MiFID II amendments, seeks to enhance transparency, efficiency, and security in EU financial markets. It strengthens investor protection, reduces market fragmentation, and simplifies trade reporting. A key focus is to harmonize different regulations – MiFIR, European Market Infrastructure Regulation (EMIR), and Securities Financing Transaction Regulation (SFTR) – while standardizing data formats for clearer, more consistent, and less burdensome reporting.

In the UK, post-Brexit reforms under the FCA’s Wholesale Markets Review follow a similar direction, with final rules anticipated by the end of 2025.

With significant changes already in motion, both EU- and UK-regulated firms must ensure their systems are sufficiently flexible to comply with current requirements and forthcoming adjustments.

Let’s look at some of the details.

Post-trade transparency for investment firms

The scope of post-trade transparency is expanding beyond the current “Traded on a Trading Venue” (ToTV) standard. For OTC derivatives, new criteria, borrowed from EMIR, now consider factors like liquidity, central clearing, and clearing obligations – helping ensure more meaningful public reporting. Regulatory Technical Standards (RTS), which define how firms should report, are also evolving: RTS 1 (equity and equity-like instruments) and RTS 2 (non-equity instruments) are being updated to improve data accuracy and market transparency.

New rules also introduce designated publishing entities (DPEs), allowing investment firms to report OTC transactions via an Approved Publication Arrangement (APA), without needing a Systematic Internalizer status.

Deferral mechanisms for trade reporting are also being simplified – some no longer require national authority approval, while others are narrowed to specific asset classes.

Transaction reporting for investment firms

Regulatory transaction reporting is also expanding to include a different range of OTC derivatives. Similarly to post-trade transparency, the updated framework blends MiFIR’s original ToTV criteria with EMIR-like concepts such as central clearing and clearing obligations – improving the completeness and consistency of reports submitted to regulators. Updates to the standard for transaction reporting (RTS 22) aim to harmonize data across multiple regimes (EMIR, SFTR, RTS 23), with enhanced granularity and significant changes. These include the addition and modification of several data fields to identify transactions and involved entities better, and a shift from XML to JSON reporting format to support automation and improve efficiency.

Post-trade transparency for trading venues

Trading venues are seeing comparable updates. Regulatory technical standards on instrument reference data (RTS 23), volume cap (RTS 3), and order book record-keeping (RTS 24) are being revised to reflect MiFIR’s ambitious transparency goals. Like investment firms for transaction reporting, venues will also transition to JSON to support better system integration, automation, and effective data processing.

Recalibrating for real-time compliance

The MiFID Review prompts compliance systems to be equipped with monitoring engines, built-in regulatory logic, and flexible update frameworks to enable firms to apply current rules automatically while remaining on standby for those still on the horizon.

Whether it’s switching between reporting formats, adapting to updated deferral regimes, or tracking a different range of OTC derivatives, effective platforms must handle these shifts without requiring manual reconfiguration. They should streamline compliance across regions and asset classes.

Like a GPS that recalibrates in real time, these systems refine their logic using live trading data – keeping firms compliant, efficient, and prepared for what’s next in the regulatory landscape.