On 17 January 2025, ISLA submitted a response to the European Securities and Markets Authority (ESMA) Consultation Paper on the Review of RTS 22 on Transaction Data Reporting under Article 26 and RTS 24 on Order Book data to be maintained under Article 25 of MiFIR, led by ISLA’s Tony Holland in collaboration with the ISLA Regulatory Reporting Working Group.
ISLA’s key proposal is to request a complete exemption from reporting any SFTs when facing a member of the ESCB under EU MiFIR and suggest that all reporting of SFTs (regardless of the counterparty) should fall exclusively under the requirements of EU SFTR over EU MiFIR.
ISLA’s full consultation response is available here.
