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New MIFIR Validation Rules (Q2 2022) – Implementation

2022-02-03 01:02:14

Point Nine Implemented New MIFIR Validation Rules (Q2 2022)

Following the previous announcement sent on the 10th November 2021 pertaining to the European Securities and Markets Authority (ESMA) updated on its
MIFIR validation rules.

As per the ESMA announcement, the changes are expected to be released in the production environment on Q2 2022 to all National Competent Authorities (NCAs) and Approved Reporting Mechanisms (ARMs). ESMA will communicate the exact implementation dates in UAT/Production separately and we will keep you posted. 

Point nine is always committed to delivering the highest quality of service and providing the best customer experience. Even though the changes will be applicable from Q2 2022, our team of experts have proactively implemented, tested and validated the new rules since the beginning of Q1 2022. The new rules will not require any further actions from our customers.

For any clarification please contact our Onboarding Team at onboarding@p9dt.com.

Below you will find all the changes in MIFIR validation rules (colour).

MIFIR validation rules changes
Rule ID Field No FIELD Validation Rule Error Code Error Text
27 7 Buyer identification code
If LEI is used, this field shall be populated with a LEI accurately formatted and in the LEI database included in the GLEIF database maintained by the Central Operating Unit.
The following conditions shall be met for transactions executed on 3 July 2018 or later:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The InitialRegistrationDate of the LEI shall be equal or before the trading date.
  3. The EntityStatus shall be Active or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
The following conditions shall be met for transactions executed until 2 July 2018:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The EntityStatus shall be Active on the trading date or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
CON-070 Buyer LEI XXX is not valid
41 11 Buyer – date of birth Date of birth in field 11 should not be later than trading date. CON-110 Date of birth is later than trading date
43 12 Buyer decision maker code
If LEI is used, this field shall be populated with a LEI accurately formatted and in the LEI database included in the GLEIF database maintained by the Central Operating Unit.
The following conditions shall be met for transactions executed on 3 July 2018 or later:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The InitialRegistrationDate of the LEI shall be equal or before the trading date.
  3. The EntityStatus shall be Active or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
The following conditions shall be met for transactions executed until 2 July 2018:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The EntityStatus shall be Active on the trading date or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
CON-120 Buyer decision maker LEI XXX is not valid
53 15 Buy decision maker – Date of birth Date of birth in field 15 should not be later than trading date. CON-150 Date of birth is later than trading date
56 16 Seller identification code
If LEI is used, this field shall be populated with a LEI accurately formatted and in the LEI database included in the GLEIF database maintained by the Central Operating Unit.
The following conditions shall be met for transactions executed on 3 July 2018 or later:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The InitialRegistrationDate of the LEI shall be equal or before the trading date.
  3. The EntityStatus shall be Active or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
The following conditions shall be met for transactions executed until 2 July 2018:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The EntityStatus shall be Active on the trading date or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
CON-160 Seller LEI XXX is not valid
70 20 Seller – date of birth Date of birth in field 20 should not be later than trading date. CON-200 Date of birth is later than trading date
72 21 Seller decision maker code
If LEI is used, this field shall be populated with a LEI accurately formatted and in the LEI database included in the GLEIF database maintained by the Central Operating Unit.
The following conditions shall be met for transactions executed on 3 July 2018 or later:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The InitialRegistrationDate of the LEI shall be equal or before the trading date.
  3. The EntityStatus shall be Active or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
The following conditions shall be met for transactions executed until 2 July 2018:

  1. The status of the LEI shall be “Issued”, “Lapsed”, “Pending transfer” or “Pending archival”.
  2. The EntityStatus shall be Active on the trading date or if the EntityStatus is Inactive, the LastUpdateDate shall be equal or after the trading date.
CON-210 Seller decision maker LEI XXX is not valid
82 24 Sell decision maker – date of birth Date of birth in field 24 should not be later than trading date. CON-240 Date of birth is later than trading date
111 35 Net amount In case the CFI code is reported in field 43 (transaction in a financial instrument that is not admitted to trading):
The field is mandatory for debt instruments, i.e. CFI reported in field 43 is DB**** (Bonds), DC**** (convertible bonds), DT**** (mendium term notes) or DN**** (municipal bonds).
CON-350 Net amount is missing
262 35 Net amount In case the CFI code is available in the instrument reference data (transaction in an instruments admitted to trading):
The field is mandatory for debt instruments, i.e. CFI of the instrument in the reference data is DB**** (Bonds), DC**** (convertible bonds), DT**** (mendium term notes) and DN**** (municipal bonds)
CON-351 Net amount is missing
283 36 Venue
If field 25 Transmission of order indicator is ‘true’, the trading venue field should be XOFF or XXXX.
CON-362 Trading venue field is incorrect
284 37 Country of the branch membership
This field must not be populated where field 36 is populated with ‘XXXX’ or ‘XOFF’ or a MIC pertaining to a Systematic Internaliser.
CON-372 Country of branch membership is inconsistent with the MIC populated in field 36.
140 45 Notional currency 2
This field is mandatory where field 43 is populated with:

  1. Swaps with the following CFI attributes : SF****
  2. Futures with the following CFI attributes: FFC***
  3. Financial instrument with the following CFI attributes: JF****, RWC***, RFC***, DE***C and DS***C
CON-452 Notional Currency 2 is missing
250 45 Notional currency 2
This field should not be populated where field 43 is populated with:

  1. Options with the following CFI attributes: O**S**, O**D**, O**T**, O**N**
  2. Futures with the following CFI attributes: FFS***, FFD***, FFN***, FFV***, FC****
  3. Swaps with the following CFI attributes: ST****
  4. Complex options with the following CFI attributes: HT****, HE****, HF****
  5. Other classes of instruments with the following CFI attributes:
    RA****, RS****, RP****, RD****, RM****, RX****, RWB***, RWS***, RWD***, RWT***, RWI***, RWM***, RWX***, RFB***, RFS***, RFD***, RFT***, RFI***, RFM***, RFX***, E*****, C*****, DB****, DC****, DW****, DT****, DG****, DA****, DN****, DD****, DM****, DY****, DX****,
    DE***B, DE***S, DE***D, DE***T, DE***I, DE***N, DE***M, DE***X,
    DS***B, DS***S, DS***D, DS***T, DS***I, DS***N, DS***M, DS***X, JE****, JC****, JR****, JT****, JX****
CON-453 Notional currency 2 is not applicable for the given instrument
117 37 Country of the branch membership This field is mandatory where:
MIC populated in field 36 pertains to an EEA trading venue or trading platform outside the Union, excluding Systematic Internalisers (i.e. this field is not applicable can be left blank for transactions executed on Systematic Internalisers).
CON-370 Country of branch membership is missing
CON-412 If at least 7 days has passed after the transaction submission (i.e. it is the 8th day after the submission) the transaction shall be rejected with the following error message:
Instrument or MIC is not valid in reference data on transaction date
154 48 Underlying index name
This field is mandatory where field 43 is populated with

  1. Options with the following CFI attributes: O**I**, O**N**
  2. Futures with the following CFI attributes: FFI***, FFN***
  3. Entitlements with the following CFI attributes: RWI***, RFI***
CON-480 Direct underlying index name is missing
264 48 Underlying index name
This field should not be populated where field 43 is populated with:

  1. Debt instruments with the following CFI attributes: DB****, DT****, DY****
  2. Other instruments with the following CFI attributes: ES****, EP****, EC****, EF****, EL****, ED****, EM****, EX****, C****
CON-481 Underlying index name is not applicable for the given instrument
166 53 Option exercise style
Field is mandatory where field 43 is populated with:

  1. Options with the following CFI attributes: O***** or H*****
  2. Warrants with the following CFI attributes: RW**** and RF****
CON-530 Option exercise style is missing.
228 57 Investment decision within firm
Field should not be populated in reports where the transmitting firm identification code is not populated for the buyer or seller (fields 26 and 27) and the firm deals on a matched principal capacity (i.e. value ‘MTCH’ populated in field 29) or an any other capacity (i.e. value ‘AOTC’ populated in field 29) unless the decision maker field is populated with the LEI of the executing entity. This rule should be interpreted as follows:
Field 57 should be left blank (not populated) if:

  • the transmitting firm identification code is not populated for the buyer (fields 26 is blank); and
  • the transmitting firm identification code is not populated for the seller (field 27 is blank); and
  • the firm deals on a matched principal capacity or an any other capacity (i.e. value ‘MTCH’ or ‘AOTC’ is populated in field 29); and
  • any of LEIs populated in the buyer decision maker (field 12) is different from the LEI of the executing firm or field 12 is blank (no LEI); and
  • any of LEIs populated in the seller decision maker (field 21) is different from the LEI of the executing firm or field 21 is blank (no LEI).
CON-571 Investment decision identifier should not be populated in reports where the firm deals on a matched principal capacity or an any other capacity unless the decision maker field is populated with the LEI of the executing firm.


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