The Transaction Reference Number (TRN) was used under MiFID I by the reporting entity to cancel or amend transaction reports (field n°22 of table 1 in annex 1 of Implementing Regulation 1287/2006).

It was also used by competent authorities when requesting additional information related to the transaction report under MiFID reporting scheme. It was required to be consistent and persistent only at the level of a reporting entity, no matching being required with other entities.

Under the MiFID II the Transaction Reference Numbers are retained and amended to comply with the following rules:

  • it uniquely identifies every transaction report sent to the competent authorities at the investment firm level; 
  • it is a unique, persistent and consistent code at the level of the investment firm; and
  • in the particular case of a transaction report pertaining to direct execution on a trading venue, it shall be the same as generated and disseminated by the trading venue to both the buying and the selling parties when confirming the execution.

The above founding principles were reflected in the ESMA's Consultation Paper Guidelines on transaction reporting, reference data, order record keeping & clock synchronisation 23 December 2015 (ESMA/2015/1909), which prescribed the required population of respective fields of MiFID II transaction reports as regards TRNs as follows (p. 69):

clip2   Links

 

UTI - Trade ID for EMIR derivatives reporting purposes

Report Tracking Number (RTN)

"Transaction reference numbers shall be unique to the executing firm for each transaction report and shall not be re-used even where the original transaction report is cancelled, except where the original transaction report is being corrected in which case the same transaction reference number shall be used for the replacement report as for the original report that it is being amended".

The MiFID II conception for TRNs has been further developed in the Draft regulatory technical standards on reporting obligations under Article 26 of MiFIR attached to the ESMA's Consultation Paper of 23 December 2015.

In this document the Transaction Reference Number was envisioned to be populated in the Field No 2 of the Table 2 (Details to be reported in transaction reports) with the following description of this item:

"Identification number that is unique to the executing firm for each transaction report. Where, pursuant to Article 26(5) of Regulation (EU) 600/2014, a trading venue submits a transaction report on behalf of a firm that is not subject to Regulation (EU) 600/2014, the trading venue shall populate this field with a number that has been internally generated by the trading venue and that is unique for each transaction report submitted by the trading venue."

The same content to be populated as regards TRN is laid down in the MiFID II final reporting rules stipulated in the Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities (RTS 22, Annex I, Table 2 Field 2).

TRN was initially used also for the EMIR reporting purposes but the Commission Implementing Regulation (EU) 2017/105 of 19 October 2016 amending Implementing Regulation (EU) No 1247/2012 laying down implementing technical standards with regard to the format and frequency of trade reports to trade repositories according to Regulation (EU) No 648/2012 of the European Parliament and of the Council on OTC derivatives, central counterparties and trade repositories has replaced TRNs‘ use under the EMIR reporting framework (for the avoidance of confusion) with the Report Tracking Numbers (RTNs).


 

IMG 0744   Documentation

 

 

Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities, OJ L 87, 31.3.2017, p. 449–478 - RTS 22

 

ESMA's Final Report Review of the Regulatory and Implementing Technical Standards on reporting under Article 9 of EMIR of 13 November 2015 (ESMA/2015/1645)

 

Commission Implementing Regulation (EU) 2017/105 of 19 October 2016 amending Implementing Regulation (EU) No 1247/2012 laying down implementing technical standards with regard to the format and frequency of trade reports to trade repositories according to Regulation (EU) No 648/2012 of the European Parliament and of the Council on OTC derivatives, central counterparties and trade repositories.

 

Consultation Document, Review of the technical standards on reporting under Article 9 of EMIR of 10 November 2014, ESMA/2014/1352

 

ESMA's Consultation Paper Guidelines on transaction reporting, reference data, order record keeping & clock synchronisation 23 December 2015 (ESMA/2015/1909)

 

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