MiFIR Review is on track

Even before EMIR REFIT entered into force, the European Parliament published its Directive (EU) 2024/790 and Regulation (EU) 2024/791, called “MiFID II / MiFIR Review”, and already nicknamed “MiFID III / MiFIR II” or “MiFIR REFIT”. The text applies as of March 28th 2024, but “Several provisions in the MiFIR review need to be supplemented by Commission delegated regulations to become fully operational”.Concerning the reporting which is what is interesting us, Post Trade Transparency (RTS 1&2), Position Reporting (MiFID II art. 58) and of course, Transaction Reporting (RTS 22), the consultation process is running, and Final reports are expected in December 2024 and March 2025. We will then have a clearer view of the timeline, as the Commission explains in its draft notice that the set of rules applicable to reporting will become applicable as soon as the revised RTS starts applying and in the meantime the rules prior to the MiFIR Review will continue applying. Reading carefully the ESMA consultations, we can already expect substantial changes, particularly on the Transaction Reporting side. More to come early next year, keep in touch!