All financial counter-parties, some non-financial counter-parties, investment managers providing advice and portfolio management on a client-to-client basis, credit Institutions, market operators, trading venue, central counter-parties and third- country firms providing investment services or activities within Europe may find themselves in scope for transaction reporting even if they are not headquartered in Europe.

1. The Clock is Ticking!
MiFIR Final Check List

2. With the January 3, 2018 deadline less than 6 months away, we encourage firms to take the
following steps today and without any further delay, in order to ensure that MiFIR implementation
process is well thought and executed, in order for the firms to be compliant.
1. Check whether you are in scope of MiFIR
All financial counterparties, some non-financial counterparties, investment managers providing
advice and portfolio management on a client-to-client basis, credit Institutions, market operators,
trading venue, central counterparties and third- country firms providing investment services or
activities within Europe may find themselves in scope for transaction reporting even if they are not
headquartered in Europe.
2. Determine whether you are acting as a Systematic Internaliser (SI) , a Multilateral Trading
Facility (MTF) or an Organised Trading Facility (OTF).
MTF OTF SI
Definition A multilateral system
ran by an investment
firm or a market
operator, which gathers
multiple third-party
buying and selling in
financial instruments
A multilateral system
which facilitates a
multiple third-party
buying and selling
interests in non-equity
products.
An investment firm that
deals on its own
account by executing
client orders outside a
Trading Venue. Purpose
is to ensure the
internalization of order
flow by investment
firms does not
undermine the
efficiency of price
formation on RMs,
MTFs and OTFs
Financial Instruments All Non-equities only All OTC
Matching System Non-discretionary Discretionary Discretionary
Restrictions • Cannot execute
client orders against
proprietary capital
• Cannot trade on
matched principal
• Cannot deal on won
account except for
illiquid sovereign
debt
• Market making is
independent
• Matched principal is
allowed if client is
informed
• Cannot operate an
SI
• Cannot operate a
multilateral trading
system
Participants Regulated Entities Regulated and
Unregulated Entities
Clients only

3. 3. Make sure you know which of your instruments should be reported
The reportable instruments are:
Financial Instrument Product Type
Equity Shares
Depositary Receipts
Debt Instruments Bonds
Money Market Instruments
Interest Rate
Derivatives
Futures
Options
Interest Rate Swaps
Cross-Currency Swaps
Swaptions
Forward Rate Agreement
Others (e.g. exotic)
Credit Derivatives Single Name
Total Return Swaps
Swaptions
Exotic
Index Tranched
Index Untranched
Other
Equity Derivatives Futures
Forwards
Swaps
Options
Portfolio Swaps
Other (e.g. explicit hybrid)
Securitised
Derivatives
Plain Vanilla covered
warrants
Leverage certificates
Exotic covered warrants
Negotiable rights
Investment Certificates
Others
Structured Finance
Products
CDSs
Others
Financial Instrument Product Type
Commodities
Derivatives
Metals
Energy
Agricultural
Environmental
Freights
Emission Allowances
Other (e.g. fertilizer)
Currency Derivatives Futures
Forwards
Swaps
Options
Contract For
Difference (CFD)
Currency
Commodity
Equity
Bond
Others (e.g. equity on an
option)
Exchange Traded
Products
Exchange Traded Funds
Exchange Traded Notes
Exchange Traded
Commodities
Others
Emission Allowances European Union Allowance
(EUA)
European Union Aviation
Allowances (EUAA)
Certified Emission Reductions
(CER)
Emission Reduction Units
(ERU)
Other
Units in Collective Investment Undertakings
Other Derivatives

4. 4. Check your Data Collection Capability for the 65 fields
Different information required for reporting should be gathered from different sources. Make sure
you know from which source each information should be extracted.
The following information are required:
General Fields
1. Report Status
2. Transaction Reference Number
3. Trading Venue Transaction Identification Code
4. Executing Entity Identification Code
5. Investment Firm Covered by Directive 2004/39/EC or Directive 2014/65/EU
6. Submitting Entity Identification Code
11. Buyer Identification Code
12. Country of the branch for the buyer
13. Buyer- First Name
14. Buyer- Surname
15. Buyer- Date of Birth
Buyer
7. Buyer Decision Maker Code
8. Buyer Decision Maker- First Name
9. Buyer Decision Maker- Surname
10. Buyer Decision Maker- Date of Birth
Buyer Decision Maker
25. Trading Date Time
26. Trading Capacity
27. Quantity
28. Quantity Currency
29. Derivative Notional Increase/Decrease
30. Price
31. Price Currency
32. Net Amount
33. Venue
34. Country of the branch Membership
35. Up-front Payment
36. Up-front Payment Currency
37. Complex Trade Component ID
Transaction Details
16. Seller Identification Code
17. Country of the branch for the seller
18. Seller- First Name
19. Seller- Surname
20. Seller- Date of Birth
Seller
21. Seller Decision Maker Code
22. Seller Decision Maker- First Name
23. Seller Decision Maker- Surname
24. Seller Decision Maker- Date of Birth
Seller Decision Maker
38. Transmission of order indicator
39. Transmitting firm identification code for the buyer
40. Transmitting firm identification code for the seller
Transmission Details
45. Instrument Identification Code
46. Instrument Full Name
47. Instrument Classification
48. Notional Currency 1
49. Notional Currency 2
50. Price Multiplier
51. Underlying Instrument Code
52. Underlying Index Name
53. Term of the underlying Index
54. Option Type
55. Strike Price
56. Strike Price Currency
57. Option Exercise Style
58. Maturity Date
59. Expiry Date
60. Delivery Type
Instrument Details
41. Investment decision within firm
42. Country of the branch responsible for the person making the investment
decision
43. Execution within firm
44. Country of the branch supervising the person responsible for the execution
Trader and Algorithms
61. Waiver Indicator
62. Short Selling Indicator
63. OTC post-trade Indicator
64. Commodity derivative Indicator
65. Securities Financing Transaction Indicator
Indicators

5. 5. Make sure you have a LEI
All reporting firms should identify themselves with a LEI. This means that a firm should make sure
that it has acquired a LEI for itself and validate that its counterparties also identify themselves with a
LEI.
6. Personal Data: Ensure you have the required protection controls in place
MiFIR requires that firms provide some personal data (first name, surname and date of birth) for the
buyer, seller and the decision makers for both sides irrespective of their nationality. Firms should
make sure that they have the required protection controls and legal documents in place for the
distribution of these data.
7. Submit the required Instrument Reference Data
Trading venues and systematic internalisers shall provide their competent authority by 21.00 CET on
each day they are open for trading with the reference data for all financial instruments that are
admitted to trading or that are traded, including where orders or quotes are placed through their
system, before 18.00 CET on that day.
Where a financial instrument is admitted to trading or traded, including where an order or a quote is
placed for the first time, after 18.00 CET on a day on which a trading venue or systematic internaliser
is open for trading, the reference data in respect of the financial instrument concerned shall be
provided by 21.00 CET on the next day on which the trading venue or systematic internaliser
concerned is open for trading.
8. Make sure you know where you will submit your transaction report.
Transaction reports shall be made to National Competent Authorities by:
• Investment firm itself
• Approved Reporting Mechanism (ARM)
• Trading Venue
In case one of the branches of the EU investment firm reports part or all of the transactions of the
investment firm, it will have to report the transactions to the home competent authority of the
investment firm and not to the host competent authority of the branch.
In case an investment firm delegates it reporting to a trading venue or an ARM, it means that this
trading venue or this ARM will have to report to home competent authority of the investment firm
on whose behalf it reports and not to the competent authority of the Trading Venue or ARM
submitting the transaction report.
In case the non-EEA firm has only one branch within the EEA, it will report to the host competent
authority of that branch, while in case the non-EEA firm has branches in multiple jurisdictions, it will
choose one of the host competent authorities of its branches and report all transactions to the
competent authority.

6. 9. Familiarise yourself with the MiFID II glossary
Admission to trading The decision by the operator of a RM, MTF, or
OTF to allow a financial instrument to be traded
on its systems. This would include a decision
that allows any conditional trading to take
place on its systems.
Algorithm An algorithm is a set of defined instructions for
making a calculation. They can be used to
automate decision making, for instance with
regards to trading in financial instruments.
Algorithmic trading Trading in financial instruments where a
computer algorithm automatically determines
individual parameters of orders such as
whether to initiate the order, the timing, price
or quantity of the order or how to manage the
order after its submission, with limited or no
human intervention, and does not include any
system that is only used for the purpose of
routing orders to one or more trading venues
or for the processing of orders involving no
determination of any trading parameters or for
the confirmation of orders or the post-trade
processing of executed transactions.
Ancillary services Any of the services listed below:
a) Safekeeping and administration of
financial instruments for the account of
clients, including custodianship and
related services such as cash/collateral
management and excluding
maintaining securities accounts at the
top tier level
b) Granting credits or loans to an investor
to allow him to carry out a transaction
in one or more financial instruments,
where the firm granting the credit or
loan is involved in the transaction
c) Advice to undertakings on capital
structure, industrial strategy and
related matters and advice and services
relating to mergers and the purchase of
undertakings

7. d) Foreign exchange services where these
are connected to the provision of
investment services
e) Investment research and financial
analysis or other forms of general
recommendation relating to
transactions in financial instruments
f) Services related to underwriting
g) Others.
Trading in and “any other capacity” All other activity that does not come under the
definitions of own account trading or matched
principal trading shall be reported with a
trading capacity of ‘any other capacity’ which
includes the agency capacity. The buyer/seller
will be the venue or counterparty while the
client will be the seller/buyer.
Approved Publication Arrangement (APA) A system that requires firms executing
transactions to publish trade reports through a
body that ensures timely and secure
consolidation and publication of such data.
Approved Reporting Mechanism (ARM) A platform that reports transactions on behalf
of firms.
Bid-ask spread The bid-ask spread is the difference between
the price at which a market maker is willing to
buy an asset and the price it is willing to sell at.
C6 energy derivative contracts Options, futures, swaps, and any other
derivative contracts relating to coal or oil that
are traded on an OTF and are physically settled.
Central Counterparty (CCP) A legal person that interposes itself between
the counterparties to the contracts traded on
one or more financial markets, becoming the
buyer to every seller and the seller to every
buyer.
Certificates Those securities which are negotiable on the
capital market and which in case of a
repayment of investment by the issuer are
ranked above shares but below unsecured
bond instruments and other similar
instruments.
Commodity derivative A financial instrument the value of which
depends on that of a commodity, such as
grains, energy or metals.

8. Competent Authority The authority, designated by each Member
State in accordance with Article 67 of Directive
2014/65/EU, unless otherwise specified in this
Directive.
Consolidated tape provider A person authorised under this Directive to
provide the service of collecting trade reports
for different financial instruments from
regulated markets, MTFs, OTFs and APAs and
consolidating them into a continuous electronic
live data stream providing price and volume
data per financial instrument.
Continuous auction order book A system that by means of an order book and a
trading algorithm operated without human
intervention matches sell orders with matching
buy orders on the basis of the best available
price on a continuous basis.
Credit Default Swap (CDS) A credit default swap is a contract between a
buyer and a seller of protection to pay out in
the case that another party (not involved in the
swap), defaults on its obligations. CDS can be
described as a sort of insurance where the
purchaser of the CDS owns the debt that the
instrument protects.
Dealing on own account
Trading against proprietary capital resulting in
the conclusion of transactions in one or more
financial instruments.
When an investment firm is dealing on own
account it should be reported as either the
buyer or seller in the transaction report. The
corresponding seller or buyer will be the
counterparty or client or trading venue that the
investment firm is dealing with.
Depositary Receipts (DR) Those securities which are negotiable on the
capital market and which represent ownership
of the securities of a non-domiciled issuer while
being able to be admitted to trading on a
regulated market and traded independently of
the securities of the non-domiciled issuer.
Derivative A derivative is a type of financial instrument
whose value is based on the change in value of
an underlying asset.

9. Direct market access (DMA) Participants require access to a market in order
to trade on it. Direct market access refers to
the practice of a firm who has access to the
market allowing another third party firm
electronic access to the market via their own
systems.
EU Emission Allowance (EUA) An allowance to emit one tonne of carbon
dioxide equivalent during a specified period,
which shall be valid only for the purposes of
meeting the requirements of Directive
2003/87/EC and shall be transferable in
accordance with the provisions of this
Directive.
Exchange for physical (EFP) A transaction in a derivative contract or other
financial instrument contingent on the
simultaneous execution of an equivalent
quantity of an underlying physical asset.
Exchange-Traded Fund A fund of which at least one unit or share class
is traded throughout the day on at least one
trading venue and with at least one market
maker which takes action to ensure that the
price of its units or shares on the trading venue
does not vary significantly from its net asset
value and, where applicable, from its indicative
net asset value.
Execution of orders on behalf of clients Acting to conclude agreements to buy or sell
one or more financial instruments on behalf of
clients and includes the conclusion of
agreements to sell financial instruments issued
by an investment firm or a credit institution at
the moment of their issuance.
Give-up or give-in A transaction where an investment firm passes
a client trade to, or receives a client trade from,
another investment firm for the purpose of
post-trade processing.
Guarantee An explicitly documented legal obligation by a
guarantor to cover payments of the amounts
due or that may become due pursuant to the
OTC derivative contracts covered by that
guarantee and entered into by the guaranteed
entity in favour of the beneficiary where there
is a default as defined in the guarantee or

10. where no payment has been effected by the
guaranteed entity.
High frequency trading High frequency trading is a type of electronic
trading that is often characterised by holding
positions very briefly in order to take advantage
of short term opportunities in terms of price
rises and falls. High frequency traders use
algorithmic trading to conduct their business.
High-frequency algorithmic trading technique An algorithmic trading technique is
characterised by:
(a) infrastructure intended to minimise
network and other types of latencies,
including at least one of the following
facilities for algorithmic order entry: co-
location, proximity hosting or high-
speed direct electronic access
(b) system-determination of order
initiation, generation, routing or
execution without human intervention
for individual trades or orders
(c) high message intraday rates which
constitute orders, quotes or
cancellations.
Interest rate swap An interest rate swap is a financial product
through which two parties exchange flows e.g.
one party pays a fixed interest rate on a
notional amount, while receiving an interest
rate that fluctuates with an underlying
benchmark from the other party. These swaps
can be structured in various different ways
negotiated by the counterparties involved.
Investment advice The provision of personal recommendations to
a client, either upon its request or at the
initiative of the investment firm, in respect of
one or more transactions relating to financial
instruments.
Limit order An order to buy or sell a financial instrument at
its specified price limit or better and for a
specified size.
Liquid market A market for a financial instrument or a class of
financial instruments, where there are ready
and willing buyers and sellers on a continuous

11. basis, assessed in accordance with the
following criteria, taking into consideration the
specific market structures of the particular
financial instrument or of the particular class of
financial instruments:
(a) the average frequency and size of
transactions over a range of market conditions,
having regard to the nature and life cycle of
products within the class of financial
instrument
(b) the number and type of market participants,
including the ratio of market participants to
traded instruments in a particular product
(c) the average size of spreads, where available.
Market Maker A person who holds himself out on the financial
markets on a continuous basis as being willing
to deal on own account by buying and selling
financial instruments against that person’s
proprietary capital at prices defined by that
person.
Market operator A person or persons who manages and/or
operates the business of a regulated market
and may be the regulated market itself.
Matched principal trading A transaction where the facilitator interposes
itself between the buyer and the seller to the
transaction in such a way that it is never
exposed to market risk throughout the
execution of the transaction, with both sides
executed simultaneously, and where the
transaction is concluded at a price where the
facilitator makes no profit or loss, other than a
previously disclosed commission, fee or charge
for the transaction.
Money-market instruments Instruments that are very liquid and a mean of
short-term financing such as treasury bills,
certificates of deposit and commercial papers
and excluding instruments of payment.
Multilateral system Any system or facility in which multiple third-
party buying and selling trading interests in
financial instruments are able to interact in the
system.

12. Multilateral trading facility (MTF) A multilateral system, operated by an
investment firm or a market operator, which
brings together multiple third-party buying and
selling interests in financial instruments – in the
system and in accordance with non-
discretionary rules.
Order All input messages, including submission,
modification and cancellation sent to a trading
venue’s trading system relating to an order or a
quote, but excluding cancellation messages
sent subsequent to:
(i) uncrossing in an auction
(ii) a loss of venue connectivity
(iii) the use of a kill functionality.
Organised trading facility (OTF) A multilateral system which is not a regulated
market or an MTF and in which multiple third-
party buying and selling interests in bonds,
structured finance products, emission
allowances or derivatives is allowed.
Other months’ contract Any commodity derivative contract that is not a
spot month contract.
Package transaction (a) an EFP or
(b) a transaction involving the execution of two
or more: component transactions in financial
instruments:
(i) which is executed between two or more
counterparties
(ii) where each component bears meaningful
economic or financial risk which is related with
all the other components
(iii) where the execution of each component is
simultaneous and contingent upon the
execution of all other components.
Periodic auction A system that matches orders on the basis of a
periodic auction and a trading algorithm
operated without human intervention.
Portfolio management Managing portfolios in accordance with
mandates given by clients on a discretionary
client-by-client basis where such portfolios
include one or more financial instruments.

13. Portfolio trade Transactions in five or more different financial
instruments where those transactions are
traded at the same time by the same client and
as a single lot against a specific reference price.
Position limit A position limit is a pre-defined limit on the
amount of a given instrument that an entity can
hold.
Post-trade transparency Post trade transparency refers to the obligation
to publish a trade report every time a
transaction of a share has been concluded. This
provides information that enables users to
compare trading results across trading venues
and check for best execution.
Quote driven A system where transactions are concluded on
the basis of firm quotes that are continuously
made available to participants, which requires
the market makers to maintain quotes in a size
that balances the needs of members and
participants to deal in a commercial size and
the risk to which the market maker exposes
itself.
Regulated Market (RM) A multilateral system operated and/or
managed by a market operator, which brings
together or facilitates the bringing together of
multiple third-party buying and selling interests
in financial instruments – in the system and in
accordance with its non-discretionary rules – in
a way that results in a contract, in respect of
the financial instruments admitted to trading
under its rules and/or systems, and which is
authorised and functions regularly.
Relevant Operator (a) an investment firm operating a multilateral
trading facility (MTF)
(b) an investment firm operating an organised
trading facility (OTF)
(c) a market operator operating an MTF
(d) a market operator operating an OTF.
Request for quote A trading system where a quote or quotes are
provided in response to a request for quote
submitted by one or more members or
participants. The quote is executable

14. exclusively by the requesting member or
participant. The requesting member or
participant may conclude a transaction by
accepting the quote or quotes provided to it on
request.
Securities Financing Transaction (a) a repurchase transaction
(b) securities or commodities lending and
securities or commodities borrowing
(c) a buy-sell back transaction or sell-buy
back transaction
(d) a margin lending transaction.
Spot month contract A commodity derivative contract in relation to a
particular underlying commodity whose
maturity is the next to expire in accordance
with the rules set by the trading venue.
Structured finance products Those securities created to securitise and
transfer credit risk associated with a pool of
financial assets entitling the security holder to
receive regular payments that depend on the
cash flow from the underlying assets.
Systematic Internaliser (SI) An investment firm that deals on its own
account by executing client orders outside a
Trading Venue. Purpose is to ensure the
internalization of order flow by investment
firms does not undermine the efficiency of
price formation on RMs, MTFs and OTFs.
Third-country firm A firm that would be a credit institution
providing investment services or performing
investment activities or an investment firm if its
head office or registered office were located
within the Union.
Trading system The way in which an execution venue executes
orders as continuous auction order book,
continuous quote driven, request for quote and
any trading systems not covered by the
foregoing.
Trading Venue A regulated market, an MTF or an OTF.
Transferable Securities Those classes of securities which are negotiable
on the capital market, with the exception of
instruments of payment, such as:

15. (a) shares in companies and other securities
equivalent to shares in companies, partnerships
or other entities, and depositary receipts in
respect of shares
(b) bonds or other forms of securitised debt,
including depositary receipts in respect of such
securities
(c) any other securities giving the right to
acquire or sell any such transferable securities
or giving rise to a cash settlement determined
by reference to transferable securities,
currencies, interest rates or yields,
commodities or other indices or measures.
UCITS management company A company, the regular business of which is the
management of UCITS in the form of common
funds or of investment companies (collective
portfolio management of UCITS).
Undertakings for Collective Investment in
Transferable Securities Directives (UCITS)
Undertakings for Collective Investment in
Transferable Securities Directives, a
standardised and regulated type of asset
pooling, subject to harmonised EU rules and
typically devised for and marketed to retail
investors.
Voice trading system A trading system where transactions between
members are arranged through voice
negotiation.
Volume
The quantity of financial instruments traded
expressed as:
(i) the number of instruments for shares,
depositary receipts, ETFs, certificates and other
similar financial instruments;
(ii) the nominal value for bonds and structured
finance products;
(iii) the number of lots size or contracts for
derivatives;
(iv) metric tonnes of carbon dioxide for
emission allowances.