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ARTICLE · 07 MAY 2026

How Does A Regulator Or ARM Ascertain MiFIR Reportability?

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Regulators and Approved Reporting Mechanisms (ARMs) face the complex challenge of determining which financial transactions must be reported under MiFIR regulations. The Financial Instruments Reference Data Systems (FIRDS) serves as the critical infrastructure enabling this determination, but how exactly does this system work and what are its limitations?

United KingdomFinance and Banking
Quinn Perrott
Quinn Perrott
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The current application of MiFIR requires both the regulators and ARMs to filter through vast quantities of data to determine which transactions should be reported. A key component of this process is the Financial Instruments Reference Data Systems (FIRDS), established under Article 27 of MiFIR and requiring trading venues and systematic internalisers (SIs) to submit standardised reference data on financial instruments to ESMA and, in the UK, to FCA. While FIRDS is a MiFIR mechanism supporting transaction reporting and transparency requirements, it also plays an important role in assisting regulators with market monitoring under MAR and in facilitating coordination actions such as trading suspensions.

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