Here you will find information relating to the MiFID II transaction reporting regime and details of how to report to the GFSC. This page will be updated regularly.
MiFID II sets out the requirements for reporting transactions to the relevant competent authority. Reports can be provided by the firm itself or via an Approved Reporting Mechanism (ARM).
The below diagram reflects the flow of transaction reports between the various stakeholders involved in the reporting regime.
Above diagram sourced from: Technical Reporting Instructions, MiFIR Transaction Reporting’ 26 October 2016 (ESMA/2016/1521)
The information fields provided in the reports are set via EU legislation. The reporting fields, together with detail on the content to be reported is provided in EU Reporting Technical Standard 22 (EU Regulation 2017/590).
The following document provides information on:
- Details of how to submit a transaction report to the GFSC;
- Points to take in to consideration when populating the respective fields;
- Validation reports submitting entities can expect to receive.
MiFID II Transaction Reporting, Technical Specification
The GFSC held a webinar on Friday 22 September 2017 that provided details on how to submit transaction reports to the GFSC.
Access to the GFSC reporting system
To register as a user on the GFSC’s transaction reporting system, the relevant registration form is to be completed and returned via email to infoTRS@gfsc.gi
There are two registration forms:
Firms using an ARM, should ensure that the ARM also completes a registration form.
ESMA has published a Q&A which includes questions on the transaction reporting regime. You will find the Q&A here.
Below is a list of questions that the GFSC (directly from industry or via the working group) has been asked in relation to transaction reporting.
Q.1 Will the GFSC accept transaction reports from ARMs?
A.1 Yes, a firm can submit the reports directly to us or use the services of an ARM to do this. Firms intending to use an ARM are asked to notify the GFSC of this and provide details of the ARM to be used.
Q.2 What is the National Identifier (for natural persons) for Gibraltar?
A.2 It is the Passport number. The second option is the CONCAT, however this is only to be used where a passport number does not exist.
Q.3 What are the fees for transaction reporting?
A.3 The current fee is 3p per transaction. We are reviewing the transaction reporting fees as part of MiFID II implementation. Any changes to fees will be communicated once available.
Q.4 Will the GFSC be providing a process for the reporting of instrument reference data, as required under RTS 23?
A.4 The GFSC will collate this information from relevant trading venues and will arrange for this to be sent to ESMA.
Q.5 How can I register with the GFSC to submit transaction reports?
A.5 Submitting entities need to complete a registration form and submit this via email to infoTRS@gfsc.gi.
There are two registration forms; one for firms and one for ARMs. If a firm is using an ARM then both forms should be submitted (one by the firm and one by the ARM).
Once the registration request has been processed, an email will be issued with instructions, credentials and a certificate to support FTPS.
Q.6 For firms using ARMS, do both the firm and ARM need to register with the GFSC?
A.6 Yes. This is to enable both the firm and the ARM access to the relevant data submitted and issued by the GFSC in respect of the firm’s transaction reports. The firm will be granted access to the GFSC Cloud for the purposes of obtaining reconciliation reports.
Q.7 When will the GFSC get back to a firm once a registration request has been made?
A.7 We envisage to revert to firms/ARMS within 2 weeks of receipt of the registration request.
Q.8 What are the timelines for testing?
A.8 Functional and non-functional tests between the firm and the GFSC will be carried out and will run from 6th November to 15th December. The following cycles will be observed:
Cycle 1 - Integration Testing between Submitting Entity and GFSC
6 Nov – 17 Nov
The first round of integration testing will validate connectivity testing, generation of application header and validity of submission against XSD, and reference data rules. Submission response will be tested.
Cycle 2 - Integration Testing between Submitting Entity and GFSC
20 Nov – 1 Dec
The second cycle of integration testing will include scripts to test transaction lifecycle, content validation and status reports
Cycle 3 - Pre-production testing
4 Dec – 15 Dec
Pre-production testing will be driven on an ad-hoc basis should it be found that re-tests or further functional testing be required.
Q.9 Will you be providing test (script) packs?
A.9 No. The GFSC will set specific parameters to enable firms to demonstrate various reporting scenarios to us. Further details on the testing process will be provided post-registration (to the GFSC transaction reporting system).
Q.10 Will you be providing reconciliation files?
A.10 Yes. Reconciliation reports can be requested by a member on the firms or ARMs authorised personnel list (provided to us at the time of registration) by ‘sending an email to infoTRS@gfsc.gi.
The email should include the firms LEI, start and end date. The report will be issued on the GFSC Cloud on a best efforts basis.
If you have any queries in relation to transaction reporting, please do contact us at: infoTRS@gfsc.gi