AMF MiFIR transaction reporting in France
Every French-authorised investment firm files transaction reports to the AMF the day after the trade. The obligation flows from Article 26 of MiFIR — Regulation (EU) 600/2014 — and applies to every transaction in financial instruments admitted to trading on an EU venue or with an EU underlying. The reports feed ESMA’s transaction-reporting database for market-surveillance purposes. The AMF runs strict data-quality validation. This piece walks through what gets reported, when, in what format, and where most reporting projects lose time.
1. Legal basis
- Regulation (EU) 600/2014 (MiFIR) — Article 26 sets the transaction-reporting obligation
- Commission Delegated Regulation (EU) 2017/590 — the implementing RTS specifying the data fields and validation rules
- ESMA’s MiFIR Transaction Reporting Guidelines — the operational reference text
- AMF Règlement Général and dedicated AMF notices — French operational rules
2. Who files
- French-authorised investment firms (PSIs) executing transactions in financial instruments — the primary scope
- Credit institutions when providing investment services
- Branches of EU investment firms in France, for transactions executed through the branch
- Branches of third-country investment firms in France, where they are subject to MiFIR scope
The reporting firm is the one executing the transaction on its own account or for the account of a client. Where the firm transmits an order to another firm for execution, the executing firm reports — but the transmitting firm may have a residual notification obligation under specific conditions.
3. What is reported, per transaction
The MiFIR transaction report carries 65 fields per transaction. Headline groups:
- Reporting party identification — the firm’s Legal Entity Identifier (LEI)
- Buyer / seller identification — LEI for legal entities, national ID code for individuals
- Decision-maker identification — the person or algorithm that made the investment decision
- Executing trader identification — the person or algorithm that executed
- Instrument identification — ISIN where available; CFI; underlying for derivatives
- Transaction details — date and time, price, quantity, venue, currency
- Buy / sell indicator and capacity — own account, matched principal, on behalf of client
- Waivers, indicators — short-sale, OTC post-trade flags, commodity-derivative indicators
The full field list and the validation rules are in the ESMA RTS. Reporting firms validate against the ESMA-published validation file before submission.
4. Cadence and channel
- Frequency: daily — for transactions executed on day T, report by T+1 close of business
- Format: XML against the ESMA RTS schema (current version published by ESMA, refreshed periodically)
- Channel: the AMF’s transaction-reporting submission portal, with the report uploaded as an XML file or transmitted through an Approved Reporting Mechanism (ARM)
- Acknowledgement: the AMF returns validation results within a defined window — accepted, rejected, or accepted with pending validation
5. Direct reporting vs through an ARM
Firms have two paths:
- Direct reporting — the firm submits XML directly to the AMF portal. Suitable for firms with internal middle-office capacity and the operational rigour to handle daily submission discipline.
- Approved Reporting Mechanism (ARM) — a regulated service provider that aggregates reports from multiple firms and submits to the competent authority. ARMs are themselves authorised under MiFIR Article 60.
Most mid-tier investment firms use an ARM. The direct route is more common at large institutions with deep middle-office capacity.
6. Where data-quality work concentrates
Building a clean reporting layer:
- Source-system integration — the order-management and execution-management systems need to emit MiFIR-shaped data at trade time
- Reference-data layer — LEI for every counterparty, national ID for every individual, refreshed continuously
- Validation layer — running ESMA’s published validation rules before submission
- Reconciliation layer — daily count and notional reconciliation against the trade-blotter
- Exception management — workflow for rejected reports, with SLA on resubmission
7. Interaction with other reporting
| Report | Captures | Cadence |
|---|---|---|
| MiFIR transaction reporting (Article 26) | Transactions in financial instruments | Daily, T+1 |
| EMIR trade reporting | Derivatives contracts | Daily, T+1, to a trade repository |
| SFTR transaction reporting | Securities-financing transactions | Daily, T+1, to a trade repository |
| COREP-IFR | Prudential information | Quarterly |
The four sit on overlapping data sources but feed different supervisory functions. Building a single source of truth for trade data that feeds all four is the operational target.
8. FAQ
Does MiFIR transaction reporting apply if I don’t trade myself?
The obligation is on the executing firm. If you operate as an introducer transmitting orders to another firm for execution, the executing firm reports. You may have a residual notification obligation in specific cases — check Article 26(4) MiFIR.
How does this differ from the Spanish equivalent?
Same EU framework. The Spanish investment-firm transaction-reporting flows to CNMV. The French equivalent flows to AMF. The XML schema, the fields, and the validation rules are identical EU-wide.
What is an LEI and why does it matter?
Legal Entity Identifier — a 20-character ISO 17442 code identifying every legal entity. Mandatory for every legal-entity counterparty in a MiFIR report. Counterparty without an LEI = report rejected.
What if a retail customer doesn’t have a national ID I can use?
The ESMA RTS specifies acceptable national-identifier types per country of residence. Where the customer cannot provide one, defined fallback identifiers (CONCAT codes) apply. Building the look-up rules into the reporting flow is operational work.
Does AMF run inspections on reporting quality?
Yes. AMF’s data-quality team monitors reporting patterns and runs targeted inspections where data quality is low. Persistent issues feature in supervisory dialogue and, in cases of systemic failure, sanctions.
What changes under MiFIR Refit?
The MiFIR Refit (Regulation (EU) 2024/791) revises the transaction-reporting framework in defined respects — including consolidating reporting through a single mechanism and refining some of the field definitions. ESMA is updating the technical standards; the timeline for application is set in the Regulation itself.
9. What to do, today
- If you are scoping a new French investment firm, build the transaction-reporting layer alongside the application; it goes live on day one.
- Decide direct vs ARM submission early; the operational footprint differs.
- Build the counterparty reference-data layer once and reuse it across MiFIR, EMIR, SFTR.
- Run the ESMA-published validation rules before submission; resubmission discipline is critical.
- Track MiFIR Refit closely — the framework is mid-revision.
Related: AMF MiFID II investment firm · COREP under IFR/IFD · Investment firm authorisation in Spain
