Approved Publication Arrangement (APA) Reporting

Under MiFIR, MiFID investment firms are required to publicly disclose certain trade details in a timely manner following execution of a transaction outside a trading venue. The obligation applies to all MiFID investment firms, buy-side and sell-side, when dealing in instruments that are traded on a trading venue (TOTV).

Which products are reported?

Saxo Bank will report all trading in offline bonds traded

Who reports?

Unlike transaction reports, only one counterparty should make the post-trade report public (to ensure volumes are not double counted) and there is a clear reporting hierarchy. This logic is the same for Equity and Equity like instruments and Non-Equity instruments.

  • Where a trade is executed on a trading venue (such as a Multilateral Trading Facility, Organised Trading Facility or Regulated Market), it is the trading venue’s obligation to report.
  • Where two MiFID investment firms trade on a bilateral basis:
  • If one of the firms is a systematic internaliser (SI) in the relevant instrument they will always have the post-trade reporting obligation.
  • If neither firm is an SI, or if both firms are SIs, the seller of the instrument will have the post-trade reporting obligation.
  • If a MiFID investment firm trades with a non-EU firm, the MiFID investment firm will always have the post-trade reporting obligation.

Importantly, in contrast to MiFID I, MiFIR does not allow investment firms to deviate from this reporting hierarchy by agreeing between themselves which party is responsible for reporting (for example, brokers will no longer be able to agree with their clients that the broker will always be responsible for reporting, although clients may be able to arrange for their broker to assist them in submitting

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