Transaction Reporting
Transaction reporting is a regulatory requirement in MiFIR which is designed to increase the post-trade transparency on the financial markets. Nasdaq collects transaction information from non-investment firms using in order to report transactions on your behalf.
Position Reporting
All exchange and clearing members with positions in commodity derivatives need to submit a daily report (T+1) of all positions and the end beneficiary of those. Nasdaq offers two alternative models for position reporting.
Remit Reporting
One of the key directives under REMIT is the obligation for market participants to report wholesale energy market contracts, including orders to trade to ACER. Nasdaq offers a complete REMIT Trade Reporting Service for our members.
Order Record Keeping
MiFID II requires all trading venues to keep a database of all their order records for at least five years. Members must supply additional data at order entry. This is described in the order record keeping guide.
Transaction Reporting for Non-Investment Firms
Reporting for exchange members not subject to MiFIR
Full File Solution
The full file solution is used with INET/Genium INET for all markets/NDTS and is an XML file formatted according to ESMA guidelines. The file is submitted by the member to Nasdaq. Nasdaq validates the file and sends it to FSA.
Short Code Enrich
The short code enrichment solution is used with Genium INET, commodities. Short codes are submitted with each order or trade entry to supply additional information needed for the regulatory transaction reporting.
This solution is suited for members with mainly proprietary trading. If the company has significant post-trade processing, the full file submission solution will be a better fit.
Nasdaq MiFID II TRS
Investment firms trading on Nasdaq markets as well as non-members have access to support with their MiFID II transaction reporting.
Depending on the specific need and trading model, Nasdaq provides support with drafting TRS reports. Nasdaq can also transfer a customer-provided file or spreadsheet into a correctly formatted and validated XML report and return it to the customer or approved reporting mechanism (ARM) for further submission to the relevant FSA.
Similarly, feedback files from the FSA to the customer that are delivered to Nasdaq can be converted from complicated XML status reports to easily accessible and understandable data through the TRACK reporting system. TRACK offers customers the ability to easily correct and resend their reports.
Position Reporting
MiFID II-compliant position reporting for the commodities market
Nasdaq Commodities offers both FCA schema position and automated reporting.
Reporting Obligations
All exchange and clearing members with positions in commodity derivatives must submit a daily report (T+1) of all positions and the end beneficiary of them. Reporting obligations are defined in the MiFID II EU directive. Nasdaq offers two alternative models for position reporting.
FCA schema position reporting
The primary method used by investment firms for position reporting is to send an ITS 4-style file to Nasdaq on a daily basis. The file format, commonly known as the "amended FCA schema", was developed together with the FIA, EFET and Europex and is based on the FCA (Competent Authority for the UK) schema.
Automated position reporting
The alternative method for position reporting is to subscribe to the automated service offered by Nasdaq. For more information about the service, contact regulatoryreporting@nasdaq.com.
REMIT Reporting
Efficient reporting of wholesale energy contracts to ACER and Equias
Spend less time on regulatory reporting by using the Nasdaq REMIT reporting service.
Delegate the reporting of your energy contract orders and trades to Nasdaq. We offer a complete REMIT trade reporting service that covers the power derivatives markets.
REMIT Reporting Obligations
One of the key directives under the EU Regulation on Wholesale Energy Market Integrity and Transparency (REMIT) is the obligation for market participants to report wholesale energy market contracts, including orders to trade, within the EU to the Agency for the Cooperation of Energy Regulators (ACER).
According to REMIT, the wholesale energy market encompasses both spot markets and derivative markets. The reporting obligation includes both exchange traded and OTC contracts.
Regulatory Reporting Services
Nasdaq's REMIT reporting service is part of our regulatory reporting solution. The regulatory reporting services also include trade repository reporting under EMIR and MiFID II transaction reporting to local financial supervisory authorities (FSAs) through our Approved Reporting Mechanism (ARM) data reporting service ARM.
Order Record Keeping
MiFID II obligation to collect and maintain data
Obligation to Collect and Maintain Certain Data
Under Article 25 of MiFIR, operators of trading venues are required to collect and maintain relevant data relating to all orders in financial instruments which are advertised through their systems for at least five years. Within the five-year period, competent authorities may request these records of orders and transactions maintained by investment firms and trading venues.
As part of this requirement, MiFIR requires trading venues to collect the following additional data on orders, as defined in RTS 24:
- Client identification code (LEI, national ID, AGGR, PNAL)
- Investment decision within firm (national or algorithm ID)
- Execution within firm (national or algorithm ID)
- Registered trader (user ID)
- Direct electronic access (true or false)
- Liquidity provision activity (true or false)
Approach to Collecting Client and Personal Data
With regards to the mechanisms of record keeping of orders and transactions, Nasdaq took into consideration a number of factors, including regards for the sensitive nature of the data, consequences of the potential impact of additional data on latency and considerations for a solution synchronized with the industry. Nasdaq's approach can be described in the graphic.
Nasdaq implemented solutions for its equity (INET) and derivatives markets (Genium INET) where client and personal data is identified through short codes at order entry. Prior to order entry or at the latest by the end of the day, members need to supply information mapping each short code to an LEI, national ID or algorithm ID to allow Nasdaq to complete its order records in the format required by MiFIR. Members are expected to use persistent short codes to represent legal entities and physical persons over time, which means that only the delta mapping of short codes added during the day needs to be uploaded to Nasdaq on a daily basis.
Contact Exchange Services: +46 8 405 7700 or EMO@Nasdaq.com
Resource Center
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- Nasdaq Guide Transaction Reporting Version 1.4 Open
- Nasdaq Commodities Position Reporting Open
- Nasdaq Member Portal Short Code Management CSV File Format Specification Open
- ESMA Guidelines for the Full File Solution Open
- TVTIC Manual Open
- Venue Product Codes and Definition of Spot Month Open
- Venue Product Codes List Open
- Standard FCA Schema Open
- Nasdaq Guide on Order Record Keeping v.2.3 - Valid from September 16, 2022 Open
- Short Code Administration in the Member Portal Open
- Nasdaq Member Portal Short Code Management API Open
- Member Portal SFTP Access Guide Open