From the days of the first draft of MiFID I, as "principles-based" regulation, market participants started to use the term "the devil is in the detail".  Nothing is a truer example of that point than when you start to look at the reference data issues around regulatory reporting for compliance with MiFID II/MiFIR.

Back in December 2014 ESMA issued draft technical standards as part of its industry consultation that closed in March of this year, and those drafts included definitions of the reference data that market participants would need to use for regulatory reporting.  ESMA is now working on the results of that consultation, but has recently said that it still expects to issue its final standards this September.   Last December ESMA also put out a consultation about which protocol would be preferred by market participants for transaction reporting.  The FIX Protocol was one of the options addressed.

Bringing together a Reference Data Subgroup within the EMEA Regulatory Subcommittee of the FIX Trading Community is a very timely and cost-effective way for all market participants to get involved in generating an industry-wide, open, non-proprietary and standardised approach to regulatory reporting.  The initial work has started on MiFID II/MiFIR, but there are clearly other EU regulations that can be turned to once this initial work is completed.  The work being done can also act as a very firm foundation on which market participants around the world can also build when looking at regulatory reporting in jurisdictions outside the EEA.

Participants in the Reference Data Subgroup already include representatives of exchanges, major sell-side firms, Approved Reporting Mechanisms (ARMs), data vendors and software providers.  They are sharing their knowledge and experience to ensure that the FIX Protocol can do the job that the industry needs.  If MiFID II/MiFIR impacts your organisation - it's time to get involved!