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MIFIR Annex II – Validator (ESMA Q&A – Question 2)

2021-03-05 01:03:27

ESMA has set the rules for the Natural Persons Identifiers to be used in MIFIR transaction reporting.

In accordance with ESMA Q&A (Question 2) the table ‘MIFIR Annex II’ shows the list of national client identifiers for natural persons to be used in transaction reports pursuant to the priority specified in Annex II of the Commission Delegated Regulation (EU) 2017/590 (CDR). Question 2 refers to the CDR of Article 6 (1) and (4) of the designation to identify natural persons for CONCAT format which is provided below.

Article 6 Designation to Identify Natural Persons 

A natural person shall be identified in a transaction report using the designation resulting from the concatenation of the ISO 3166-1 alpha-2 (2 letter country code) of the nationality of the person, followed by the national client identifier listed in Annex II based on the nationality of the person. 

Where the identifier assigned in accordance with paragraph 2 refers to CONCAT, the natural person shall be identified by the investment firm using the concatenation of the following elements in the following order: 

  1. the date of birth of the person in the format YYYYMMDD; 
  2. the five first characters of the first name; 
  3. the five first characters of the surname. 

Point Nine applies national identifiers validation based on the priority as specified in Annex II of RTS 22. 

Point Nine Notifications Samples

Priority Check:

  • Identifier type CCPT should not be used for Buyer 12121212E on trade id [BBG] BB20210228X1426021:1. 1st priority for Spain is NIDN.
  • Identifier type CONCAT for Buyer 19000101JOHNNBOHOL on trade id [BBG] BB20210228X1426022:1 is the 2nd priority. 1st priority for United Kingdom is NIDN.
  • Identifier type CONCAT for Execution within firm 19000101JOAHABOHOL on trade id [BBG] BB20210228X1426023:1 is the 2nd priority. 1st priority for Cyprus is CCPT.
  • Identifier type CCPT for Seller 12121212E on trade id [BBG] BB20210228X1426024:1 is the 2nd priority. 1st priority for Portugal is NIDN.

Pattern Check:

  • Seller identifier 12121212E does not match the pattern of CCPT for Portugal on trade id [BBG] BB20210228X1426024:1.
  • Seller identifier AN12121212 does not match the pattern of CCPT for Cyprus on trade id [BBG] BB20210228X1426025:1.
  • Buyer identifier AX1212121 does not match the pattern of NIDN for Italy on trade id [BBG] BB20210228X1426026:1.

Samples of population natural persons identifiers

Samples Annex II of RTS 22
Type First Name Last Name Nationality Date of Birth Identifier Type Identifier
Client 1 Jean Cocteau French 4 June 1962 CONCAT FR19620604JEAN#COCTE
Client 2 Jose Luis Rodriguez de la Torre Spanish 27 February 1976 TAX Id Number 99156722T
Representative 1 Fabio Luca Italian 11 October 1974 Fiscal Code ABCDEF1234567890
Trader 1 Peter Morgan Canadian 25 May 1955 Passport Number 1112223334445555
Trader 2 Peter Jones UK 12 June 1976 National Insurance Number AB123456C
Trader 3 John Cross Belgian 2 October 1980 National Number 12345678901
Trader 4 Marie Claire French 2 December 1963 CONCAT FR19631202MARIECLAIR
Trader 5 Juliet Stevens Finnish 10 March 1962 Personal Identity 311280-888Y
Trader 6 Adam Jones Hungarian 13 April 1980 CONCAT HU19800413ADAM#JONES

MIFIR RTS 22 Annex II

Table of Annex II
ISO 3166 Country 1st Priority 2nd Priority 3rd Priority
    National client identifier Format of the identifier Potential source of the information National client identifier Format of the identifier Potential source of the information National client identifier
AT Austria CONCAT
BE Belgium Belgian National Number (Numéro de registre national – Rijksregisternummer) 11 numerical digits where the first 6 are the date of birth (YYMMDD), the next 3 are an ordering number (uneven for men, even for women) and the last 2 a check digit. National ID CONCAT
BG Bulgaria Bulgarian Personal Number It consists of 10 digits. The first 6 are the date of birth (YYMMDD). The next 3 digits have information about the area in Bulgaria and the order of birth, and the ninth digit is even for a boy and odd for a girl. Seventh and eighth are randomly generated according to the city. The tenth digit is a check digit. Passport, National ID, Driving Licence CONCAT
CY Cyprus National Passport Number The number for passports issued before 13/12/2010 consists of the character ‘E’ followed by 6 digits i.e E123456. Biometric passports issued after 13/12/2010 have a number that starts with the character ‘K’, followed by 8 digits. i.e K12345678 The passport is issued by the Civil Registry Department of the Ministry of Interior. CONCAT
CZ Czech Republic National identification number (Rodné číslo) It is a nine or ten-digit number in the format of YYXXDD/SSSC, where XX=MM (month of birth) for male, i.e. numbers 01-12, and XX=MM+50 (or exceptionally XX=MM+70) for female, i.e. numbers 51-62 (or 71-82). For example, a number 785723 representing the first six digits is assigned to a woman born on 23rd of July 1978. SSS is a serial number distinguishing persons born on the same date and C is a check digit. For people born before January 1st 1954 the number is without this check digit – YYXXDD/SSS (i.e. the nine-digit case). If the national identification number has ten digits, then the tenth (check) digit is the first nine digits modulo 11, unless this modulo is 10. In that case the tenth digit is 0. Therefore, the ten-digit number is usually divisible by 11. It should be noted that the special character “/” is just a separator and should be omitted in transaction reports. It is assigned to a person shortly after birth by the birth registry and does not change throughout the life of a person. It is printed on a birth certificate (paper), national ID card (laminated or plastic card), drivers licence (laminated or plastic card), and possibly other documents. Passport Number It is usually an eight digit number, but it can be longer. The passport is issued by the Ministry of the Interior of the Czech Republic. CONCAT
DE Germany CONCAT
DK Denmark Personal identity code 10 digits alphanumerical: DDMMYYXXXX The Danish personal ID is called the CPR number. It is 10 digits and does only consist of numbers [0-9]. The first 6 numbers represent the date of birth in “DDMMYY” format. The CPR number is used for unique personal identification can be found in documents such as passports, health care cards and driver’s licenses CONCAT
EE Estonia Estonian Personal Identification Code (Isikukood) It consists of 11 digits, generally given without any whitespace or other delimiters. The form is GYYMMDDSSSC, where G shows sex and century of birth (odd number male, even number female, 1-2 19th century, 3-4 20th century, 5-6 21st century), SSS is a serial number separating persons born on the same date and C a checksum. Passport, National ID, Driving license
ES Spain Tax identification number (Código de identificación fiscal) Code composed by 9 characters: 8 numbers and a control letter. Letters I, Ñ, O, and U are not used. It looks like 99111222M. Particular cases – L + 7 numbers + control letter for non-resident Spaniards unless they have DNI, where then it would look like as above. – K + 7 numbers + control letter for Spaniards under 14 unless they have DNI, where then it would look like as above. This code is in the National Identification Card (document nacional de identidad – DNI – or carnet de identidad), but it can also be found in the driving license or the social security card.
FI Finland Personal identity code It consists of eleven characters of the form DDMMYYCZZZQ, where DDMMYY is the date of birth, C the century sign, ZZZ the individual number and Q the control character (checksum). The sign for the century is either + (1800–1899), – (1900–1999), or A (2000– 2099). The individual number ZZZ is odd for males and even for females and for people born in Finland its range is 002-899 (larger numbers may be used in special cases). An example of a valid code is 311280-888Y. Passport, National ID CONCAT
FR France CONCAT
GB United Kingdom UK National Insurance number Two prefix letters, followed by six digits with one suffix letter, which is always A, B, C, or D. It looks something like this: AB123456A. The characters D, F, I, Q, U and V are not used as either the first or second letter of the prefix. The letter O is not used as the second letter of the prefix. For administrative reasons HMRC and DWP have sometimes used reference numbers which look like NINOs but which do not use valid prefixes. The administrative prefixes used are: OO, CR, FY, MW, NC, PP, PZ, TN. These should not be used. The NINO is an administrative number primarily for the use of HM Revenue and Customs (HMRC) or the Department for Work and Pensions (DWP). It can be on a plastic National Insurance card, paper card or letter from HRMC and may also be obtained from payslips, form P60, tax returns or letters from the DWP/HRMC. CONCAT
GR Greece 10 DSS digit investor share It consists of 10 digits and it is linked with the personal details of the investor (name, identity number, passport number, tax registration number). Investor share is the account of the investor in the DSS which is operated by the Central Securities Depository S.A. CONCAT
HR Croatia Personal Identification Number (OIB – Osobni identifikacijski broj) OIB consists of 11 digits. 10 digits are chosen randomly and do not contain information related to the holder of OIB. One digit is a control number. OIB is unique, unchangeable and unrepeatable. It is a permanent identification code of every Croatian citizen and legal person with head office in the Republic of Croatia. Source is National Identity Card or Internet engines but it can also be found on other personal documents. CONCAT
HU Hungary CONCAT
IE Ireland CONCAT
IS Iceland Personal Identity Code (Kennitala) Ten-digit number, where the first six are the date of birth (DDMMYY). Passport, National ID, Driving Licence
IT Italy Fiscal code (Codice fiscale) The code is unique, widespread and consistent over time and it is a combination of 16 letters and numbers (3 letters for the last name + 3 letters for the name + 5 letters/numbers for the date of birth (with different combinations to distinguish between men and women) + 4 letters/numbers for the place of birth + 1 check letter/number). Example: RSS MRO 62B25 E205 Y It can be printed on a paper card (old version) or on the National Health Service magnetic card (newer ones).
LI Liechtenstein National Passport Number The Code is a combination of 1 letter and 5 numbers. For example R00536 Passport National Identity Card Number The Code of the national ID-Card is a combination of 2 letters and 8 numbers. For example ID022143586 The number changes with each renewed ID-Card CONCAT
LT Lithuania Personal code (Asmens kodas) It is 11 digits long. Format GYYMMDDNNNC, where G is the gender (4 or 6 for women; 3 or 5 for men); YYMMDD is the date of birth; NNN – serial number; C – check digit. Passport, National ID, Driving license National Passport Number Passport or Identity card number – 8 digit number Passport, National ID CONCAT
LU Luxembourg CONCAT
LV Latvia Personal code (Personas kods) 11 numerical digits of the form DDMMYY-CZZZZ where the first 6 are the date of birth (DDMMYY) and the C is century sign (where the digit “0” is the 19th century, the number “1” – the 20th century, “2” – 21th century). Or 11 numerical digits selected randomly, where the first six digits may be separated from other digits with a hyphen Identification documents for Republic of Latvia – National ID and/or passport CONCAT
MT Malta National Identification Number 8 characters: 7 numerical digits and 1 alphabetic letter (M, G, A, P, L, H, B, Z) Each ID Card has a unique Identity Number, based on a combination of: (a) a sequential registration number in the relevant year; (b) the relevant year number (2 digits), where the year is the year of birth (for Malta-born persons) or year of registration (for nonMalta born persons), and (c) a letter designating the geographic origin of the person. The definition of the letters is given by the Public Registry Department on the registration of a birth A = applicable to Foreigners in possession of an eRes Card B = applicable to Maltese births registered in the 1800+ G= applicable to Gozitan births registered in the 1900+ H= applicable to Gozitan births registered in the 2000+ L= applicable to Maltese births registered in the 2000+ M= applicable to Maltese births registered in the 1900+ P= applicable to Maltese citizens who are unable to obtain their original birth certificate from their country of birth to be registered in Malta. Z= applicable to Gozitan births registered in the 1800+ National ID National Passport Number 7 Numerical digits Civil Registration Directorate
NL Netherlands National Passport Number 9 characters of which: Position 1 and 2: [A-Z] except for “O”; Position 3 – 8: [A-Z] [0-9] except for “O”; Position 9: [0-9]. Dutch National Passport National identity card number 9 characters of which: Position 1 and 2: [A-Z] except for “O”; Position 3 – 8: [A-Z] [0-9] except for “O”; Position 9: [0-9]. The character “O” is not allowed while “0” is. Dutch National ID CONCAT
NO Norway 11 digit personal id (Foedselsnummer) The id is 11 digits long, where the first 6 represent birthdate in “ddmmyy” format. Includes but not limited to: passport, national id card, driving license CONCAT
PL Poland National Identification Number (PESEL) 11 NUMERIC. ID for natural persons is assigned to a person shortly after birth by the birth registry and does not change throughout the life of a person Birth Certificate, National ID, Driving License Tax Number (Numer identyfikacji podatkowej) 10 NUMERIC. It is used by investment firms for the tax identification of a client. Tax form PIT8 which is sent yearly by an IF on behalf of its client to the tax office.
PT Portugal Tax number (Número de Identificação Fiscal) Code composed by one block of 9 digits (999999999). The first eight digits are sequential and the last one is used as a control: 1 to 3: Personal, 3 is not yet assigned; 45: Natural person. The initial digits “45” correspond to non-residents citizens that only get in Portuguese territory income subject to withholding at source; 5: legal person required to register in the National People Collective Registry; 6: The agencies of the Central Government, Regional or Local administration; 70, 74 and 75: Used to identify different types of Heritage Indivisible; 71: Collective non-residents subject to withholding at source definitively; 72: Investment Funds; 77: officious allocation of taxable NIF (entities that do not require NIF on the official bodies (RNPC); 78: officious assignment to non-residents covered by the proceeding VAT REFUND; 79: Exceptional rules – created in 98 exclusively to the Mundial Exposition (Expo 98); 8: “sole trader” (no longer used, is no longer valid); 90 and 91: Condos, Irregular Society and undivided inheritances; 98: Non-residents without permanent establishment; 99: Civil societies without legal personality. The passport of uniform and optical model issued before April 2018 consists of a notebook with 32 pages numbered, identified by one letter and six digits: Position 1: letter [A-Z] and Position 2 – 6: digits [0-9]. The passport of uniform and optical model issued after April 2018 consists of a notebook with 32 (requested by normal travel) or 48 (requested by a frequent travel) pages numbered, identified by two letters and six digits: Position 1-2: letter [A-Z] and Position 3 – 8: digits [0-9]. Portuguese National Passport CONCAT
RO Romania National Identification Number (Cod Numeric Personal) The Romanian National ID (Cod Numeric Personal, CNP) consists of 13 digits and is created by using the gender of the citizen and century (1 digit, 1/3/5/7 for men, 2/4/6/8 for women and 9 for foreign citizens), date of birth (6 digits, YYMMDD), the place of birth (2 digits), followed by a serial number (3 digits) and 1 control digit, at the. The first digit encodes the person’s gender as follows: 1 Male born between 1900 and 1999 2 Female born between 1900 and 1999 3 Male born between 1800 and 1899 4 Female born between 1800 and 1899 5 Male born after 2000 6 Female born after 2000 7 Male, foreign citizen, RO resident 8 Female, foreign citizen, RO resident 9 Foreign citizen The CNP is a unique identifying number, assigned to each person at birth and, is inscribed on Birth Certificate, Identity Card and Driving License. National Passport Number The Romanian Passport Number consists of 9 digits. Romanian National Passport CONCAT
SE Sweden Personal identity number Personal identity number: 12 digits numerical in the format CCYYMMDDZZZQ CCYYMMDD is the date of birth, ZZZ the individual serial number, and Q is the control character (calculated with Luhn-algoritm). The individual number ZZZ is odd for males and even for females. CC is century, YY year, MM month and DD day. NB! The 12 digits numerical format is used, as the official 10 digits numerical format of the personal identity number includes a separator (YYMMDD-ZZZQ or YYMMDD+ZZZQ if the person has turned 100) which severely complicates data processing and storage. Personal identity number is used for unique personal identification. This number, in its official 10 digits numerical format (i.e. excluding the CC for century and including a separator), is written on or into various personal documents such as passports, health care cards, and driver’s licenses. CONCAT
SI Slovenia Personal Identification Number (EMŠO: Enotna Matična Številka Občana) It consists of 13 digits. The first 7 numbers represent the date of birth of the person – DDMMYYY. Digit 8 and 9 represent the number of a register where EMŠO was assigned: • 10-19 – Bosnia and Hercegovina (if signed in before 18 February 1999) • 20-29 – Montenegro (if signed in before 18 February 1999) • 30-39 – Croatia (if signed in before 18 February 1999) • 40-49 – Macedonia (if signed in before 18 February 1999) • 50-59 – Slovenia (if signed in before 18 February 1999, if later number 50 is used) • 60-69 – (not in use) • 70-79 – Serbia (if signed in before 18 February 1999) • 80-89 – Autonomous Province of Vojvodina (if signed in before 18 February 1999) • 90-99 – Kosovo (if signed in before 18 February 1999)). Digit 10, 11 and 12 are a combination of gender and serial number for persons, born on the same day (000-499 for male and 500-999 for female). Number 13 is a control number and is calculated by a special procedure, defined in Article 4 of the Regulation on the way of assigning the personal identification number (Nos. no. 8/99). Slovenian Personal Identity Card Slovenian National Passport CONCAT
SK Slovakia Personal number (Rodné číslo) The Personal Number consist of ten digits in the form YYMMDDCCCX. The first part is created from the date of birth (differently for male and female): YY – the last 2 digits of the year of birth; MM – month of birth for male (01 -12), month of birth plus 50 for female (51-62); DD – day of birth; CCC- number distinguishing persons born on the same date; X – check digit. The Person Number must be divisible by 11. It is printed on a birth certificate (paper), national ID card (laminated or plastic card), drivers licence (laminated or plastic card), and possibly other documents. National Passport Number It is issued in the format XXNNNNNNN. It is a 9-digit unique code where XX are block letters and NNNNNNN are numbers. It has a validity of 10 years. Citizens can have two passports and this code can only be found on the first one. CONCAT
All other countries   National Passport Number CONCAT

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