Germany – BaFin Post-Trade Transparency

On 17 October, BaFin proposed rules on MiFIR post-trade transparency.

  • Covers post-trade transparency obligations for debt, equity and derivative trades.
  • MiFIR requires securities companies to report on debt and derivative transactions.
  • There is exemption from the general obligation if authorized by national regulator.
  • BaFin stated delayed publication is suitable means of balancing legitimate interests.
  • Waives requirement to publish limited details of several transactions in aggregate.
  • But reserves the right to revoke the exemption at any time if not in public interest.


  • Comments due by 14 November 2017.

U.K. – FCA MiFID Passporting

On 16 October, FCA issued statement on MiFID passporting using Connect.

  • Firms wishing to passport under MiFID I one can use Connect up until 3 December 2017.
  • From 4 Decemebr, firms can still use Connect but system will reflect MiFID II framework.
  • Means the firms will have to submit one passport notification for each country used.
  • But firms can not select MiFID II specific passport activities on Connect until 3 January.
  • Firms wishing to passport from 3 January or new authorizations should apply by email.
  • FCA encourages firms to submit emails to in good time.