MiFID APA Reporting

Enhancing Transparency and Investor Protection

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MiFID APA Reporting

Cappitech recently expanded its regulatory solutions to include support for MiFID APA (Approved Publication Arrangement) reporting, enabling firms to meet evolving market transparency requirements.

What is MIFID APA Reporting?

MiFID APA reporting is a regulatory obligation under the Markets in Financial Instruments Directive (MiFID II), designed to increase market transparency and protect investors. The process requires firms to make information about executed trades publicly available through an Approved Publication Arrangement (APA). By publishing trade details, regulators and market participants gain greater visibility into market activity, helping to promote fair and efficient markets.

What needs to be reported and when?

MiFID APA reporting covers a broad range of financial instruments, including all types of securities and derivatives—both exchange-traded (ETD) and over the counter (OTC). The regulation stipulates strict publication deadlines to ensure timely access to market data:

Equity Trades: Must be reported to an APA within one minute of execution.
Non-Equity Trades: Must be reported within five minutes.

Depending on the instrument and market conditions, publication can be immediate or deferred, allowing firms to balance transparency with operational considerations.

Is MIFID APA a Single or Dual-Sided Reporting?

MiFID APA is a single-sided reporting requirement. The responsibility to report falls on one party, which may be:

A Qualifying Investment Firm (QIF)
A Systematic Internalizer (SI)
A Trading Venue (TV), which includes Regulated Markets (RM), Multilateral Trading Facilities (MTF), or Organized Trading Facilities (OTF)

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How Cappitech can assist with MIFID APA reporting?

File Transformation: Converts trade data into the format required by APAs.

Multiple Input Format Support: Cappitech provides flexible data ingestion capabilities and supports multiple input formats, including JSON, FIX, and CSV.

APA Regime determination: Determine the applicable transparency regime for each trade and ensure the application of mandatory validations and required data enrichment.

UPI Enrichment: Perform UPI enrichment in coordination with ANNA DSB, including the lookup based on OTC ISIN and population of the applicable Unique Product Identifier for each reportable trade.

End-of-Day Reconciliation: Ensures all trades have been reported accurately and helps firms maintain robust controls over their reporting processes.

How the Cappitech Solution Works

Connect

Data collection from customer DB, file upload or API

Validate

Reports validated for eligibility & field content

Enrich

Reports enriched with static & dynamic data

Submit

Report is submitted to an ARM, and review notifications are updated to the web dashboard

See it in action

Monitor the timeliness of your reporting and drill down into the details of late submissions to identify any underlying problems in your reporting process.

Gain insights into your transaction reporting; improve KPIs on accuracy, completeness and timeliness of your submissions. Monitor and improve your rejection rates by viewing the top reasons for rejections. Historical reports for rejected trades can be viewed and analyzed, enabling firms to improve their reporting.

Automate and monitor your reporting with our multi-regulation platform, a single platform for all your transaction reporting needs. From a single dashboard you can get a visual status overview of your reported trades and review complete transaction lifecycles. Use our sophisticated filtering and search functionality to easily investigate individual trade submissions.

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Where are trades reported under MIFID APA?

Trade reports are submitted to an APA that is authorized in the jurisdiction where the firm is regulated. In Europe, APAs are authorized by the European Securities and Markets Authority (ESMA), while in the UK, the Financial Conduct Authority (FCA) provides authorization. Firms must ensure they use the correct APA to remain compliant with local regulations.

Is there any divergence between ESMA and FCA MIFID APA reporting?

Yes. Following Brexit, ESMA and the FCA became two separate and independent regulators, each responsible for setting and enforcing their own regulatory frameworks. As a result, certain rules and interpretations under MiFID have begun to diverge between the EU and the UK. This has led to differences in APA reporting requirements and supervisory expectations.

What Are the Consequences of Non-Reporting?

Failure to report trades accurately and on time can result in regulatory penalties. If a firm identifies any “material” errors or omissions in its reporting, it must submit an Errors & Omissions form, similar to requirements under EMIR Refit. Timely correction and disclosure are essential to maintain compliance and avoid enforcement actions.

By leveraging Cappitech’s technology, firms can enhance their reporting accuracy, reduce operational risk, and meet their regulatory obligations with confidence.