--- title: "ESMA Q&A 1511 — Q&A — Transaction reporting [Answer Published]" shortTitle: "ESMA Q&A 1511 — Q&A — Transaction reporting [Answer Published]" answer_id: ESMA_QA_1511 topic: "* Transaction reporting" status: "Answer Published" type: qa instrument_type: qa authority: ESMA binding: false binding_character: non_binding legal_status: in_force regulation: "MiFIR" mifir_level3: true mica_level2: false legal_basis: "MiFIR" date: 28 September 2020 source_link: https://www.esma.europa.eu/publications-data/questions-answers/1511 lifecycle: "Answer Published" text_version: "ESMA Q&A register, 28 September 2020" source_url: "https://www.esma.europa.eu/publications-data/questions-answers/1511" check_status: matched verified: true last_checked: 2026-10-26 checked_against: "the ESMA publication" source: prepared_by: "ESMA" published_by: "ESMA" published_in: "ESMA Q&A tool" evidence: prepared_by: "ESMA Answer" locator: "ESMA Q&A entry ESMA_QA_1511: field 'ESMA Answer', no 'Answer provided by' line" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2020-09-28" question_submitted_on: "2020-09-28" locators: published_on: "ESMA Q&A Excel export ESMA_QA_1511, column 'Esma responses', date line" question_submitted_on: "ESMA Q&A Excel export ESMA_QA_1511, column 'Date of submission'" lifecycle_label: "Answer Published" --- **Answer by ESMA, published in its Q&A tool · not legislation · published 28 Sep 2020 [Answer Published]** *Answer Published · ESMA Q&A register, 28 September 2020 · Checked against the ESMA publication on 26 Oct 2026 · [Official source](https://www.esma.europa.eu/publications-data/questions-answers/1511)* | | | |---|---| | **Full title** | ESMA Q&A 1511 — Q&A — Transaction reporting \[Answer Published\] | | **Prepared by** | ESMA | | **Published by** | ESMA, in the ESMA Q&A tool | | **Reference** | ESMA_QA_1511 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 28 September 2020; question submitted 28 September 2020 | | **Legal basis** | MiFIR | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the ESMA publication | **Transaction reporting** ### Question Consider a scenario where an Investment Firm A executes a reportable transaction through an execution algorithm provided by another Investment Firm B . a) How should field 59 (Execution within firm) of RTS 22 be reported when Investment Firm A uses the execution algorithm provided by Investment Firm B? b) Would Investment Firm A’s reporting differ if Firm B was not a MiFID II Investment Firm and therefore did not have the obligation to report this transaction under Art. 26 MiFIR? c) Where Investment Firm B is using Investment Firm A’s membership to access the market, is Investment Firm B executing the transaction and does Investment Firm B have to transaction report? *** ### Answer (a) The reporting obligations are the same as where Investment Firm A decides to send an order for execution to Investment Firm B. Investment Firm A should populate field 59 with the person or algorithm identifier within their firm that is primarily responsible for using Investment Firm B’s algorithm. Investment Firm A shall not populate a code for Investment Firm B’s algo, only its own information. The scenario is: IF A → IF B (algorithm) → CCP (Trading Venue or Investment Firm) Assuming that Investment Firm A is buying an instrument and dealing on own account trading capacity, and Investment Firm B is acting in “any other” trading capacity, the respective reports should be completed as follows: N Field Investment Firm A’s report Investment Firm B’s report 4 Executing entity identification code {LEI} of Investment Firm A {LEI} of Investment Firm B 7 Buyer identification code {LEI} of Investment Firm A {LEI} of Investment Firm A 16 Seller identification code {LEI} of Investment Firm B {LEI} of CCP 29 Trading capacity ‘DEAL’ ‘AOTC’ 59 Execution within firm Natural person’s ID or code of algorithm within Investment Firm A Code for Investment Firm B’s execution algorithm (b) No. Investment Firm A’s reporting is the same as specified in a). (c) Yes. Investment Firm B is conducting the activity of executing a client order according to Art. 3 of RTS 22\[1\]. The scenario is: IF A → IF B (algorithm) → IF A (membership) → CCP (Trading Venue) Assuming that both Investment Firm A is buying an instrument and dealing on own account, and the subsequent steps in Investment Firm B and A are in “any other” trading capacity, the respective reports should be completed as follows: N Field IF A’s report 1 IF B’s report IF A’s report 2 4 Executing entity identification code {LEI} of Investment Firm A {LEI} of Investment Firm B {LEI} of Investment Firm A 7 Buyer identification code {LEI} of Investment Firm A {LEI} of Investment Firm A {LEI} of Investment Firm B 16 Seller identification code {LEI} of Investment Firm B {LEI} of Investment Firm A {LEI} of CCP 29 Trading capacity ‘DEAL’ ‘AOTC’ ‘AOTC’ 59 Execution within firm Natural person’s ID or code of algorithm within Investment Firm A Code for Investment Firm B’s execution algorithm ‘NORE’ In order to match Investment Firm B’s reports and reflect its involvement in more than one part of ‘the chain’, Investment Firm A has to submit two reports: one for its trade as a client with Investment Firm B (Report 1). one for its market-side trade with the Central Counterparty or another Investment Firm (Report 2). \[1\] Commission Delegated Regulation (EU) 2017/590. *** **Source:** [ESMA original document](https://www.esma.europa.eu/publications-data/questions-answers/1511)