ESMA has updated the Questions and Answers document on MiFIR data reporting, which can be found here. Most of the requirements apply to Investment Firms and Market Operators. Energy and commodity traders will need to comply with these rules if they lose their exemptions, which in many cases will be determined by MiFID II Article 2(1)j and RTS 20 which outlines the Ancillary Activity test.

The contents of the test, RTS 21 on position limits and also a brief overview of the reporting requirements will be given at a training course to be held jointly by Entrima and ETR Advisory in London on 21st February. Further details can be found here.