About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

IHS Markit Prepares SI Register to Support MiFID II Reporting

Subscribe to our newsletter

IHS Markit is preparing a registry of systematic internalisers (SIs) to help market participants comply with Markets in Financial Instruments Directive II (MiFID II) trade reporting obligations. The SI list will go live at the end of November on Markit’s Counterparty Manager web portal and will detail SIs operating across European Securities and Markets Authority (ESMA) RTS 2 asset classes including investment bonds, OTC derivatives, equities and equity-like instruments, and structured products.

The Markit SI service will address the MiFID requirement that when one party to a transaction executed off-venue or on a non-European venue is an SI, that party is responsible for reporting trades on a near real-time basis. This means knowing the SI status of counterparties will become a key part of trade reporting workflow.

Markit says regulators will list SI firms, but claims its register will provide more granular data. Brie Lam, Markit director of regulatory and compliance services, explains: “ESMA will publish a list of all firms that have notified their EU national competition authority (NCA) that they are SIs. However, if a dealer registers as an SI for only a narrow class of instruments and an investment firm transacts off venue with that dealer in a different type of instrument, that firm could be responsible for reporting. That’s why it’s important to know the full scope of the dealer’s SI registration at a granular level.”

She adds: “Dealers are likely to adopt a range of strategies in complying with the SI regime. Some will opt to register broadly across multiple asset classes and others will register on a granular basis for only the products in which they have significant trade volume. Our registry provides on-demand access to SI status, giving firms full pre- and post-trade transparency for whether they are subject to reporting rules on any given trade.”

Markit has designed the SI register to support trade reporting workflow and give investment firms a mechanism for disseminating SI status to Approved Publication Arrangements (APAs) and their clients. The service was developed in consultation with the International Swaps and Derivatives Association (ISDA), broker-dealers, APAs and other industry groups.

Subscribe to our newsletter

Related content

WEBINAR

Recorded Webinar: Best Practices for Managing Trade Surveillance

The surge in trading volumes combined with the emergence of new digital financial assets and geopolitical events have added layers of complexity to market activities. Traditional surveillance methods often struggle to keep pace with these changes, leading to difficulties in detecting sophisticated market abuses and increased regulatory risk. To address these challenges, financial institutions are...

BLOG

Genesis Global Enhances Financial App Development Platform with End-User Reporting Controls

Genesis Global has announced a significant update to its AI-native application development platform for financial markets, giving end-users direct control over the creation, modification and distribution of reports based on application data. The enhancement marks a shift from traditional development practices, where changes to reporting functions would typically require developer intervention and code adjustments. The...

EVENT

TradingTech Summit London

Now in its 15th year the TradingTech Summit London brings together the European trading technology capital markets industry and examines the latest changes and innovations in trading technology and explores how technology is being deployed to create an edge in sell side and buy side capital markets financial institutions.

GUIDE

The DORA Implementation Playbook: A Practitioner’s Guide to Demonstrating Resilience Beyond the Deadline

The Digital Operational Resilience Act (DORA) has fundamentally reshaped the European Union’s financial regulatory landscape, with its full application beginning on January 17, 2025. This regulation goes beyond traditional risk management, explicitly acknowledging that digital incidents can threaten the stability of the entire financial system. As the deadline has passed, the focus is now shifting...