On 20 September 2019, the Malta Financial Services Authority (the “MFSA”) issued a circular on the go live of MiFID II XML Schema version 1.1.0, aiming to provide further information and technical remarks about the go live of the new portal. The publication follows the release of technical remarks about the MiFID II Phase 2 First Round of Testing, the notice on the availability of the MiFID II phase 2 testing portal through the Managed File Transfer solution and the updates on the TREM XML schema version 1.1.0 go-live date, issued by the MFSA on the 12 August 2019, 6 February 2019 and 11 February 2019, respectively.
Under MiFIR, reporting of transactions to the national competent authorities (“NCAs”) has to be performed in accordance with the requirements set out by the Transaction Reporting Guidelines and Transaction Reporting Exchange Mechanism (“TREM”). ESMA guidelines specify the construction of transaction reports field by field for the various trading scenarios. Each of the scenarios is accompanied with an example of the XML text to be used to represent the specific reportable values. The guidelines are supplemented by relevant technical documents specifying the mechanism for reporting entities to submit transaction reports to NCAs and the mechanism to be used by them to exchange such reports among them.
ESMA regularly updates the XML Schema used for reporting transaction data as well as the reporting instructions and the validation rules and, on 23 September 2019, has gone live with version 1.1.0 of the XML Schema, which supersedes XML Schema version 1.0.3. Only submissions making use of the XML Schema version 1.1.0 will be accepted on and after the go live date.
On the same date ESMA has also updated the Financial Instruments Reference Data System (“FIRDS”) reference data reporting system. From 23 September 2019 onwards, trading venues and systematic internalisers obliged to submit reference data for the relevant financial instruments to NCAs should use the new XML Schema 1.1.0 to report to FIRDS, as this will be the only format supported.
A two-days’ maintenance window of the MFSA’s system was scheduled on 21 and 22 September 2019 in order to transition from the old schema (FIRDS XSD 1.0.0 and TREM XSD 1.0.3) to the new XML Schema and perform system upgrades. Friday 20 September 2019 was the last day for reporting data using the old XML Schema and during the maintenance window was not possible to report data; any transaction backlog occurred during this period should be reported using the new schema.
From 23 September 2019 reporting entities should only use the new XML Schema 1.1.0 to report transaction data, as this will be the only format supported.
A copy of the MFSA circular can be obtained by clicking here.
Should you require any assistance in this regard, please contact Andrew Caruana Scicluna (andrew.caruanascicluna@camilleripreziosi.com) or Giuseppe Gigante (giuseppe.gigante@camilleripreziosi.com).
