Transaction Reporting

Here you will find information relating to the MiFID II transaction reporting regime and details of how to report to the GFSC.  This page will be updated regularly.



MiFID II sets out the requirements for reporting transactions to the relevant competent authority.  Reports can be provided by the firm itself or via an Approved Reporting Mechanism (ARM).  

The below diagram reflects the flow of transaction reports between the various stakeholders involved in the reporting regime.

Above diagram sourced from: Technical Reporting Instructions, MiFIR Transaction Reporting’ (ESMA/2016/1521)

The information fields provided in the reports are set via EU legislation.  The reporting fields, together with detail on the content to be reported is provided in EU Reporting Technical Standard 22 (EU Regulation 2017/590).


Technical Specifications

The following document provides information on:

  • Details of how to submit a transaction report to the GFSC;
  • Points to take in to consideration when populating the respective fields;
  • Validation reports submitting entities can expect to receive. 

MiFID II Transaction Reporting, Technical Specification

XML Schema Changes

Our Transaction Reporting system has been updated to accommodate the XML Schema v1.1.0. The changes came into effect on Monday 23 September 2019. For more information, please click here.

If you have any queries relating to the above, please contact [email protected] 



The GFSC held a webinar on Friday 22 September 2017 that provided details on how to submit transaction reports to the GFSC. 


Access to the GFSC reporting system

To register as a user on the GFSC’s transaction reporting system, the relevant registration form is to be completed and returned via email to [email protected] 

There are two registration forms:

Firms using an ARM, should ensure that the ARM also completes a registration form. 



ESMA has published a Q&A, which includes questions on the transaction reporting regime, and Guidelines on transaction reporting, order record keeping and clock synchronisation under MiFID II

Below is a list of questions that the GFSC (directly from industry or via the working group) has been asked in relation to transaction reporting.  

Q.1 Will the GFSC accept transaction reports from ARMs?

A.1 Yes, a firm can submit the reports directly to us or use the services of an ARM to do this.  Firms intending to use an ARM are asked to notify the GFSC of this and provide details of the ARM to be used.

Q.2 What is the National Identifier (for natural persons) for Gibraltar?

A.2 It is the Passport number.  The second option is the CONCAT, however this is only to be used where a passport number does not exist. 

Q.3 What are the fees for transaction reporting?

A.3 The fee is 3p per transaction.This is set out in the Financial Services Commission (Fees) Regulations 2016.

Q.4 Will the GFSC be providing a process for the reporting of instrument reference data, as required under RTS 23?

A.4 The GFSC will collate this information from relevant trading venues and will arrange for this to be sent to ESMA.


Q.5 How can I register with the GFSC to submit transaction reports?

A.5 Submitting entities need to complete a registration form and submit this via email to [email protected]

There are two registration forms; one for firms and one for ARMs.  If a firm is using an ARM then both forms should be submitted (one by the firm and one by the ARM).

Once the registration request has been processed, an email will be issued with instructions, credentials and a certificate to support FTPS.

Q.6 For firms using ARMS, do both the firm and ARM need to register with the GFSC?

A.6 Yes.  This is to enable both the firm and the ARM access to the relevant data submitted and issued by the GFSC in respect of the firm’s transaction reports.  The firm will be granted access to the GFSC Cloud for the purposes of obtaining reconciliation reports.

Q.7 When will the GFSC get back to a firm once a registration request has been made?

A.7 We envisage to revert to firms/ARMS within 2 weeks of receipt of the registration request.  


Q.8 Will you be providing reconciliation files?

A.8 At present, this function is not available.

As we currently do not provide data samples, firms can, as set out in Article 15(4) of RTS 22, reconcile front-office trading records against the information contained in the transaction reports submitted directly, or via ARMS, to us.   

Transaction reporting

Q.9 Are transactions in funds reportable? 

A.9 Transactions in a unit of a collective investment undertaking or an exchange traded fund are only reportable if the unit of a collective investment undertaking or the exchange traded fund is itself admitted to trading or traded on a trading venue or a request for admission has been made. Sections of the ESMA Guidelines on Transaction Reporting explains reporting exclusions relating to collective investment schemes under Article 2(5)(g) of EU Regulation 2017/590. 

Q.10 When does a decision maker not need to be reported? 

A.10 Where a firm executes a transaction at the request of a client (i.e. the decision to buy is therefore made by the client) the decision maker fields in the transaction report are to be blank (an example of this is set out in section 5.9.1 of ESMA Guidelines).   Where a power of attorney (POA) is exercised on behalf of a client, then the client would be reported as the buyer with the third party (exercising the POA) reported as the decision maker (a transaction reporting example is provided in Section 5.9.2 of the ESMA Guidelines)


If you have any queries in relation to transaction reporting, please do contact us at: [email protected]