Investment firms must disclose the details of the transactions that they have executed in financial instruments (and all instruments derived from financial instruments) that are traded or admitted to trading on a trading venue (regulated market, MTF or OTF), regardless of the place of execution. Investment firms can report their own transaction information, but they can also do this via a company that acts as an Approved Regulatory Mechanism (ARM). They can also report via a trading venue of which the systems were used to execute the transaction.
Trading venues are responsible for reporting transactions on their venues for members who are note investment firms. This information must be reported completely and accurately and as quickly as possible to the supervisor (in any case no later than at the end of the following working day).
The above-mentioned obligation for investment firms does not only apply to the execution of orders, but also to accepting and transmitting orders and taking investment decisions. Furthermore, it is required to provide the client's personal details per transaction. For natural persons, the notification must include a national passport number. If the customer does not have a passport, a national identification number must be used, and if the customer does not have this either the final possibility is a so-called CONCAT. A legal entity identifier (LEI) must be used for legal entities. This can lead to a considerable effort on the part of investment firms and trading venues and customers might also be expected to take part in the process.