ESMA has updated the various documents around MiFID II transaction reporting, as outlined in RTS 22 (see here). The Reporting Instructions document has been updated and can be found here. A log of changes can be found here. The resulting schemas can be found here.

The instructions document specifies how the reporting works, including report validation. There is a detailed description of ISIN validation, a topic which requires careful consideration in view of the requirement for many derivatives to have ISIN codes. This post on LinkedIn by Sassan Danesh of eTrading Software provides an update on the latest status of the ANNA- DSB – the derivatives service bureau which generates ISIN codes for derivatives (see here)

Investment Firms that are subject to the MiFID II reporting requirements must comply with the rules either by submitting reports to the relevant National Competent Authority (NCA), an Authorised Reporting Mechanism (ARM) or sometimes by delegation to the relevant venue.  This will include energy and commodity traders who have to seek authorisation either because they cannot pass the Ancillary Activity test, or due to carrying out other regulated activity.