The European Securities and Markets Authority (ESMA) has issued final guidelines on the implementation of the transaction reporting regime under MiFID II. The guidelines, https://www.esma.europa.eu/press-news/esma-news/esma-provides-guidance-transaction-reporting-order-record-keeping-and-clock aimed at investment firms, trading venues and approved reporting mechanisms (ARMs), provide further detail on how to implement the transaction reporting, order record keeping and clock synchronisation requirements.

MiFID II comes into force in 2018 and the guidelines also provide examples of XML-messages to be used to represent the expected reportable values.

Transaction reporting under MiFID II

ESMA's guidelines include:

• Transaction reporting and order record keeping: high level approaches and further guidance on specific legislative provisions on transaction reporting and order record keeping, e.g. the meaning of transaction, the concepts of “order” and “member or participants of a Trading Venue”
• Reporting and record keeping scenarios for the various trading scenarios that may occur: in particular, transaction reporting resulting from transmissions of orders, grouped orders, and the provision of Direct Electronic Access (DEA); and order record keeping in the case of central limit order books and request for quotes systems.
• Reporting specific financial instruments: most examples are focused on derivatives given that these financial instruments have a more complex reporting pattern.
• Clock synchronisation: further guidance on specific legislative provisions, e.g. the concepts of “reportable events” and “gateway-to-gateway latency”.