MiFIR reporting will have considerably more fields and a wider scope than MiFID, ensuring that you not only know where this data is, but also that it can be accessed is vital. There are project tools available, such as our MiFIR Accelerator, for you to compare your data against the RTS to asses its readiness.

Some of the new fields include sensitive personal data fields, such as individuals’ ID numbers, names and birthdates. Some solution providers, such as UnaVista, can provide functionality to assist with masking and separation of the data.

There are a number of different Approved Reporting Mechanism (ARMs) and Approved Publication Arrangement (APAs) available in the industry; ensure the select a service can offer not just complete compliance, but additional services to help your business meet the regulators' expectations.

Regulators will not be tolerant of firms who simply report everything without checking eligibility. Sourcing a reliable list of instruments that are eligible for MiFIR transaction reporting will help avoid any over-reporting and the inefficiencies this creates.

ESMA is not only looking for firms’ reporting to be timely and accurate, it also expects to see the appropriate systems and controls in place. This includes providing the appropriate training courses for all relevant staff. UnaVista offers a certified foundation training course to give staff the best grounding.

ESMA have been clear that firms "should" be reconciling their reported data, ensuring that firms have done as much as possible to provide accurate data. Any ARM you select should be able to offer this as part of their service.

Governance for staff who are involved in transaction reporting is essential to ensure best practice in effectiveness and appropriate accountability.