ESMA updates MiFIR validation rules (Q2 2022)

October 20, 2021

ESMA have published a new version (1.6) of MIFIR Validation Rules document.

The changes include: 6 new validation rules, updated 14 existing validation rules and updated error text for one of the existing validations.

The changes will be applicable from Q2 2022, however the exact implementation date has not been communicated yet.

Update 28/03/2022:

Today ESMA have communicated the go-live for the 1.6 version of changes to be 31/05/2022.

At the same time ESMA have publised version 1.7 of changes, further clarifying rules 027, 043, 056, 072 previously changed by v.1.6.

Update 11/04/2022:

We have received an update from FCA on implementation of the changes published by ESMA.

FCA decided to not enforce the changed/new rules.  They are however happy for firms to “implement these additional and other validations should they wish to, where they feel this will improve the data quality of their submissions”.

Update 31/05/2022:

Between 03/12/2021 and 31/05/2022 Control Now have been executing these validations as a part of the TR Accuracy offering to allow clients to prepare for upcoming changes. All validations are named after the Rule ID (e.g. for Rule ID 041 – CN validation is MT041). Please see 03/12 Release Notes (item 12).

As of 01/06/2022 these validations have been included in the MiFIR Core Validations module and removed from TR Accuracy to avoid duplication. Please see 31/05 Release notes.

Change type Rule ID Error code Affected field(s) Rule Description
New 041 CON-110 Buyer – date of birth (11) Date of birth for affected fields should not be later than trading date.
053 CON-150 Buy decision maker – Date of birth (15)
070 CON-200 Seller – date of birth (20)
082 CON-240 Sell decision maker – date of birth (24)
Changed 027 CON-070 Buyer identification code (7) Included clarification that the ‘EntityStatus’ of LEI reported in affected fields shall be ‘Active’ on the trading date.
043 CON-120 Buyer decision maker code (12)
056 CON-160 Seller identification code (16)
072 CON-210 Seller decision maker code (21)
Changed 111 CON-350 Net Amount (35) Field ‘Net Amount’ is made mandatory for additional groups of products (previously only DB**** (Bonds)). Added products CFI codes: DC**** (convertible bonds), DT**** (medium term notes) and DN**** (municipal bonds).
See Control Now TR Accuracy MI: ‘Bonds Pricing MI’
262 CON-351
Changed 270 CON-361 Venue (36) Added clarification that for population of ‘XXXX’ in ‘Venue’ field. If ‘Instrument Identification Code’ is provided, then it must not be present in reference data for the relevant trade date.
New 283 CON-362 Clarified that transactions executed directly on venues cannot be transmitted (when ‘Transmission of order indicator’ is ‘true’, the ‘Venue’ field should be XOFF or XXXX).
See Control Now TR Accuracy MI: Transmission of order indicator.
Changed 117 CON-370 Country of the branch membership (37) Clarified that field ‘Country of the branch membership’ should not be optional for SIs.
New 284 CON-372 Clarified that field ‘Country of the branch membership’ must be blank for SIs, XOFF and XXXX.
Changed 220 CON-412 Instrument identification code The error text is amended to include also MIC identification. The validation rule itself is not changed.
Changed 140 CON-452 Notional currency 2 (45) Field is now mandatory for wider range of currency products (previously only currency swaps (SF****) and currency futures (FFC***)).
Added products: currency forwards (JF****), warrants on currencies (RWC***), mini-future certificates/constant leverage certificates on currencies (RFC***), Structured instruments without capital protection on currencies (DE***C) and Structured instruments – capital protection on currencies (DS***C).
Changed 250 CON-453 Notional currency 2 (45) Field must be blank for wider range of products: non-currency products from groups: entitlements, debts, forwards (RA****, RS****, RP****, RD****, RM****, RX****, RWB***, RWS***, RWD***, RWT***, RWI***, RWM***, RWX***, RFB***, RFS***, RFD***, RFT***, RFI***, RFM***, RFX***, DB****, DC****, DW****, DT****, DG****, DA****, DN****, DD****, DM****, DY****, DX****, DE***B, DE***S, DE***D, DE***T, DE***I, DE***N, DE***M, DE***X, DS***B, DS***S, DS***D, DS***T, DS***I, DS***N, DS***M, DS***X, JE****, JC****, JR****, JT****, JX****).
Changed 154 CON-480 Underlying index name (48) Field is now also mandatory for index based mini-future certificates/constant leverage certificates (RFI***). Added to index based options (O**I**, O**N**), futures (FFI**, FFN***) and entitlements (RWI***).
264 CON-481 Field must be blank for wider range of equity products and collective investment vehicles (previously only chosen debt products (DB****, DT****, DY****)).
Added products: ES****, EP****, EC****, EF****, EL****, ED****, EM****, EX**** and C****.
Changed 166 CON-530 Option exercise style (53) Field is now also mandatory for Mini-future certificates/constant leverage certificates  (RF****). Previously only options (O***** and H*****) and warrants (RW****).
Changed 228 CON-571 Investment decision within firm (57) Included clarification for cases when fields ‘Buyer decision maker code’ and ‘Seller decision maker code’ are left blank.


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