Amendments to L1 MiFIR

November 15, 2023

The European Council has recently put forward amendments to the L1 text of MiFIR (Markets in Financial Instruments Regulation). This piece aims to summarise the key changes that will impact reporting obligations.

Upcoming Steps

  1. Adoption by Parliament: Expected in Q1 2024.
  2. Drafting of Updated RTS 22 by ESMA: Following adoption, the European Securities and Markets Authority (ESMA) will have 18 months to draft updated RTS 22 in accordance with MiFIR Article 26 (9).
  3. Implementation Period: It is anticipated to be up to 18 months, though this is yet to be confirmed.



Ref Item Description Reference
1 NCAs Increase in obligation for NCAs sharing reporting data MiFIR Article 26(1)
2 OTCs in scope Off-venue OTC trades which fall within the clearing obligation added to transaction reporting requirements MiFIR Article 26(2)
3 Identification of firms subject to reporting obligation Added to L1 texts, new requirement MiFIR Article 26(3)
4 TvTIC Added to L1 texts, from RTS 22 MiFIR Article 26(3)
5 Short selling flag Removed from L1 texts MiFIR Article 26(9d)
6 Operators of venues Clarified delegated reporting obligation for operators of venues. Updated from ‘firm’ to ‘Any member, participant or user’ MiFIR Article 26(5)
7 Branch Reporting Added to L1 texts, from RTS 22 MiFIR Article 26(8)
8 Effective dates Added to L1 texts, from RTS 22 MiFIR Article 26(3, 9c)
9 Waivers Removed from L1 texts MiFIR Article 26(3, 9c)
10 Linking of aggregated orders New requirement. Exact requirements to be confirmed in RTS MiFIR Article 26(9j, 9k)
11 Reporting review Commitment for a more detailed review within 4 years MiFIR Article 26(11)
12 Fund managers Commitment to review scope of reporting requirements include to AIFMs, and management companies within 12 months MiFIR Article 52 (14b)


These amendments mark significant changes in the regulatory landscape, specifically in the realm of financial reporting. Stakeholders are advised to stay updated on these developments, especially as they progress through the legislative process.

Control Now can help you seamlessly manage such changes as amendments and modifications are automatically integrated into our software.

For more details, including a demo of our products, please contact:



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