17 May 2021


MiFID II/MiFIR: Changes to transaction reporting according to Article 26 (5) MiFIR for non-MiFIR firms

Eurex Circular 043/21 MiFID II/MiFIR: Changes to transaction reporting according to Article 26 (5) MiFIR for non-MiFIR firms

1.    Introduction

As announced in the T7 Release announcement on 29 April 2021, Eurex Frankfurt AG will replace the technical infrastructure of the Regulatory Reporting Hub (RRH) in the course of 2021.

The RRH has been used by Eurex Frankfurt AG in order to fulfil its requirements according to Article 26 (5) Regulation (EU) 600/2014 (“MiFIR”). According to this Article, Eurex Frankfurt AG is responsible for the transaction reporting of Trading Participants, which are not subject to MiFIR (in the following referred to as non-MiFIR Trading Participants).

With T7 Release 10.0 on 22 November 2021, Eurex Frankfurt AG will migrate to a new technical solution within Deutsche Börse AG’s infrastructure. As part of this migration process, the SFTP server currently being used for up-/downloads of non-MiFIR Trading Participant data will be replaced by:

  • the Common Upload Engine (CUE) as a central SFTP connection point for non-MiFIR Trading Participants to upload transaction data and data of end clients for trades in AOTC capacity, if applicable,
  • the Common Report Engine (CRE) as a central SFTP connection point for non-MiFIR Trading Participants to download transaction data (extract file and feedback file).

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2.    Required action for non-MiFIR Trading Participants

A. Migration to the new CUE/CRE solution by 22 November 2021

Non-MiFIR Trading Participants are required to migrate to the new CUE/CRE solution for the non-MiFIR transaction reporting by 22 November 2021. The simulation environment will be available with the T7 Release 10.0 simulation, which is planned to take place between 13 September 2021 and 19 November 2021.

B. Adjustment of interfaces to the new file structure

In addition, non-MiFIR Trading Participants need to adapt their interfaces to the new file structure as the reporting solution will be redesigned. Further details will be provided in the “Regulatory Reporting Solution for non-MiFIR Trading Participants user manual” and a sample file, which will be published in July 2021.

3.    Details

The new upload functionality will be provided via the CUE in order to upload non-MiFIR Trading Participant transactions including data of end clients, if applicable.

The new download functionality will be provided via the CRE in order to download extract files and feedback files. On the CRE and the CUE, the new folder ‘MiFID’ will be available for the provision of data by the non-MiFIR Trading Participants and for the provision of the extract and feedback files. 

The technical connection to the CUE will be established in the same manner as to the CRE system. The Member Section of Deutsche Börse Group will be used for the respective account management in order to set up the technical connection to the CUE, i.e. enabling upload of the technical key certificates using the Member Section’s key generator feature.

Extract files will be provided in the CRE’s ‘MiFID’ folder at the end of day T. The CSV extract files will be generated per operating MIC and on LEI level. Thus, for a non-MiFIR Trading Participant, there will be one CSV file per operating MIC covering all transactions of its Member IDs. The structure of the extract and feedback files will be simplified, and only missing fields need to be uploaded. There will be one feedback file only.

Furthermore, non-MiFIR Trading Participants are required to submit transactions, including data of the end client, if applicable, in a CSV file latest by 18:00 CET/CEST on T+1. Upload files can be provided to the CUE’s “MiFID” folder by any of the Member IDs of the non-MiFIR Trading Participant.

Please note that a GUI will not be provided for the new non-MiFIR transaction reporting solution. 

Further information


All Trading Participants of Eurex Deutschland and Vendors

Target groups:

Front Office/Trading, Middle + Backoffice, IT/System Administration, Auditing/Security Coordination, Compliance departments, Nominated Persons


Your Key Account Manager or, 
for regulatory related questions:


Authorized by:

Michael Peters

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