CN MAKES REPRESENTATION TO ESMA: MiFIR – ID for GB nationals

April 24, 2019

CN have identified a discrepancy between the format of a GB National Insurance Number (NINO) expected by the ESMA for MiFIR data reporting, and the format expected by the HMRC.

The ESMA statement of data format doesn’t allow for the following prefixes;

“The administrative prefixes used are: OO, CR, FY, MW, NC, PP, PZ, TN. These should not be used.” (ESMA Q+A MiFIR Data Reporting Q2)

However, the HMRC list a different set of prefixes which aren’t used on their website.

In summary, the following discrepancies have been identified.

Prefixes not allowed by ESMA but are allowed by HMRC Prefixes not allowed by HMRC but are allowed by ESMA
CR BG
MW GB
KN
NK
NT
ZZ

 

CN have requested ESMA for comment on the correct interpretation of the requirements.

** If you have a query on the interpretation of reporting requirements, please contact us **