The MiFID II directive and the MiFIR regulation entered into force on 3 January 2018. The new rules apply to all firms providing investment services or activities. Transaction reporting in accordance with MiFID II/MiFIR occurs through the TRS 2 system that entered into operation on 3 January 2018. The system is open 24/7, except during service disruptions.
Investment firms executing a transaction with a financial instrument must submit details of the transaction to FI as quickly as possible – and no later than at the close of the following business day (Article 26 of MiFIR). This reporting obligation applies to significantly more instruments and trading venues than in the old MiFID regulation. NOTE: The old TRS system, which was used for reporting of transactions in financial instruments with a trading date up to and including 2 January 2018 in accordance with MiFID, has been closed.
Information published on this page will be related to reporting to the TRS 2 system's production environment. For information about test reporting to TRS 2, see Test reporting in the TRS2 system
- After Brexit (since 2021-01-01), FI has been receiving questions from submitting entities about potentially incorrect instrument validations in the transaction reporting (both that transactions in non-EEA instruments have been incorrectly approved and that correctly reported transactions were rejected with the error code CON-361).
The underlying cause is that the instrument reference data as it is received from ESMA contains rows where the PublicationFromDate and PublicationToDate fields are empty ('NULL'). Since these rows do not contribute information about the order in which reference data rows are to be sorted so that the most recently published row can be identified, these rows are not used in the instrument validation. Consequently, an instrument that has been terminated in FIRDS in conjunction with Brexit can continue to be viewed as valid based on the most recent PublicationFromDate-principle and thus be used for validations of transactions with TradeDates after 2020-12-31.
ESMA is implementing a solution for empty PublicationFromDate/PublicationToDate fields that is preliminarily planned to be implemented at the end of June 2021. The new implementation is expected to apply going forward, but not historically.
- On Tuesday, 26 January, TRS 2 will be closed for maintenance. It will still be possible to submit TR files, but feedback will not be sent until the maintenance has been completed.
- Maintenance of TRS2 system planned for beginning of January 2021 in conjunction with Brexit
Due to Brexit, ESMA will have a maintenance window from 31 December 2020 through (preliminarily) 7 January 2021. For more information, go to "ESMA updates Brexit statements for the end of UK transition period (ESMA)".
During this period, there will be no new reference data from ESMA. Instead, the TRS 2 system will validate transactions against the most recently available reference data – as per 30 December 2020. Once FI has received updated reference data from ESMA, the TRS 2 system will need to be closed for maintenance.
Due to the service windows at both ESMA and FI related to Brexit, it is possible that some transactions could be assigned the status "PDNG", remain at "PDNG" for seven days, and then become "RJCT" since correct reference data will still not have been received from ESMA. There may also be other disruptions to the TRS 2 flow.
On Friday, 16 October, from 1:00 PM to 4:00 PM, TRS 2 will be closed for maintenance. It will still be possible to send in TR files during this period of time, but feedback will not be sent until after 4:00 PM.
- From 5:00 PM on Thursday, 24 September, until noon on Monday, 28 September, TRS 2 will be closed for an upgrade. It will still be possible to send in TR files, but feedback will not be sent out until at the earliest Monday, 28 September.
- On Friday, 28 August, TRS 2 will be closed for maintenance.
It will be possible to submit TR files, but you will not receive any feedback until at the earliest Monday, 31 August.
- The IP addresses for the production and test environment will change for TRSII SFTP. This change will go into effect on 24 February. Companies can already change their configuration to use DNS.
The production environment will change from the IP address to sftp://trsii.fi.se.
The test environment will change from the IP address to sftp://trsiitest.fi.se.
Anyone who needs to continue to use an IP address should contact email@example.com for more information, but please note that you are responsible for changing your configuration no later than 24 February.
The service disruptions in the TRS 2-system are now solved. Feedback files will be generated in turn and can therefore be delayed another day.
There are currently service disruptions in the TRS 2 system. It is possible to submit new files, but no Feedback files are being generated at the moment. It could also take some time to receive the Feedback files after the issue has been fixed since there will be many files to generate.
An announcement will be published as soon as the system is running again
- The TRS 2-system is now available. Feedback files will be generated but with some delays.There are temporary issues with the TRS 2-system.
- The TRS 2 system will close on Saturday, 21 September, for an upgrade to the new version. Once the system is available again on 23 September, the new validation rules and new XML schema as previously announced by ESMA will be in effect, see previous announcement below. In the new version of the system, feedback of accepted transactions will be "delivered" in the feedback files (FF). The version is available for testing in our Test system, Test reporting in the TRS2 system.
- The European Securities and Markets Authority (ESMA) has announced that the transition to the new XML Schema and updated validation rules will occur on Monday, 23 September 2019.
More information is available at ESMA's website (pages 2–3 in the document).
FI will provide more information about the test environment.
Transaction Reporting Guidelines and Transaction Reporting Exchange Mechanism (TREM)
- The TRS 2-system is now again available.
- From Thursday 20 June untill Monday 24 June the TRS 2-system will not be available due to an update.
- The European Securities and Markets Authority (ESMA) has announced that the planned transition to the new XML Schema and updated validation rules will occur on Monday, 18 February 2019. New versions of the reporting instructions, XML Schema and validation rules are available on ESMA's website under Transaction Reporting Guidelines and Transaction Reporting Exchange Mechanism (TREM) and under Technical specifications further down on this page. PLEASE NOTE: The new versions are marked NEW: Applicable from 18 February 2019. FI will make it possible to test the new XML schema and validation rules in the TRS 2 system's test environment as of 8 January 2019. For more information, please refer to the Update list on the page Test reporting in the TRS2 system.
- On Wednesday, 12 December, the TRS 2 system will be down due to an upgrade to a new system version. It will still be possible to submit transaction files. However, the files will be retrieved from the submitting entities' FTP servers for processing first after the system upgrade is completed. The (FF) feedback files will be generated and sent at that time.
The new system version contains:
1. changes in the validation of Buyer/Seller/BuyerDecisionMaker/SellerDecisionMaker LEI codes originally with the status Inactive on TradeDate (CON-070/CON-120/CON-160/CON-210) but that have later been updated to Active in GLEIF;
2. a correction since the validation of LEI codes has previously been based on the time stamp in InitialRegistrationDate instead of the date (without the time).
- Friday, 7 December: The TRS 2 system is currently unable to create FD files (daily feedback), although it is still possible to send transaction files. FF files (direct reporting) are still being generated as usual. The FD files will not be generated again until Thursday, 13 December, at the earliest.
- On Monday, 26 November, TRS 2 was upgraded to a new system version. The new system version contains improved functionality for transaction exchanges between supervisory authorities, changes related to the scanning and handling of reference data and the following updates:
1. a change regarding error codes CON-411 and CON-412
CON-411 was issued if the instrument was missing in the reference data.
CON-412 was issued 1) immediately (without waiting seven days) if the instrument was not valid at a trading venue on the trading date and 2) if the instrument was still missing after seven days.
After the upgrade:
CON-411 will be issued 1) if the instrument is missing in the reference data or 2) if the instrument is not valid on the trading date (for seven days). The transaction report is given the status "PDNG".
CON-412 is issued only if seven days have passed and no valid instrument is found in the reference data. The transaction report is given the status "RJCT".
2. correction for improperly issued error code CON-023 ("Transaction report with the same transaction reference number has already been sent for the firm and not cancelled") for re-reporting of transactions that first have been recalled within the same TR file.
- Finaninspektionen has re-created the previously missing FD feedback that has been possible to re-create using existing technical functionality in the system. Re-created FD files containing reporting of "old" transactions have been uploaded to the Incoming folders on rapporteurs' FTP servers. Please note that the file name of these FD files uses the date the feedback was re-created. If the reporting is still missing after these files have been processed, and if the status of some transactions is unknown/unclear, please contact Finansinspektionen: firstname.lastname@example.org. Right now, summaries of relevant transaction statuses can be offered in .csv format.
- The European Securities and Markets Authority (ESMA) has announced that in conjunction with planned system upgrades (February 2019) it will also update the existing reporting instructions, XML Schema and validation rules for transaction reporting under MiFIR. More information and new versions of the reporting instructions, XML Schema and validation rules are available on ESMA's website on the page Mifir reporting instructions under the heading Transaction Reporting Guidelines and Transaction Reporting Exchange Mechanism (TREM) on ESMA's website.
- Several file valdiation controls were added in conjunction with the most recent system upgrade on 2018-06-27. The added controls (SEX-017 – SEX-019) require, for example, that the SubmittingEntityLEI code stated in the header of a TR file is in agreement with the SubmittingEntityLEI code in the TR file itself and that only LEI codes are used in the reporting. NOTE: BIC codes are not used in the reporting to the TRS 2 system. An updated list of file validation controls is available under Technical specifications/File format validations TRS2 (file validation rules) below.
- On Wednesday, 27 June, there will be operational disturbances in the TRS2 production environment due to an upgrade to a new system version. The system performance in the new version will be improved and the improperly issued error code CON-411 (Pending instrument validation) for rejected transactions will be rectified.
- ESMA published new information on 20 June 2018 regarding the LEI requirements under MiFIR. The publication confirms that the last day for the temporary period that was brought-in in December 2017 to allow for a smooth introduction of the LEI requirements will be 2 July 2018. This means that reports filed with a transaction date after 2 July will undergo validation that the transaction date falls on the same date or later than the initial registration date for the client's LEI code. The document is available on ESMA's website and can be reached through the following link: ESMA statement on LEI requirements under MiFIR.
- On Friday, 8 June, the TRS 2 production environment will still be closed for maintenance.
- On Thursday, 7 June, the TRS 2 production environment will be closed for maintenance. It will be possible to send TR files but no feedback will be sent until the end of the day.
- On Thursday, 3 May, the TRS 2 production was upgraded to a new system version. The following bug corrections have been made:
1. Cancellations of transactions in status RCVD will now receive the status RCVD instead of RJCT with CON-024 (Transaction for cancellation cannot be found);
2. Improperly issued CON-502 (Option type does not match instrument classification);
3. Improperly issued CON-472 (Underlying instrument is not present in reference data on transaction date);
4. Improperly issued CON-370 (Country of branch membership is missing) for SI;
5. Improperly issued CON-351 (Net amount is missing) for some instruments with CFI D*****;
6. Improper RJCT on transactions with instruments traded in certain currencies, e.g. CZK and PHP;
7. Improper RJCT with CON-552 (Expiry date is incorrect) for transactions where TradeDate is the same as ExpiryDate;
8. Solution for improperly issued CON-070, CON-120, CON-160 and CON-210 (Buyer/Buyer decision maker/Seller/Seller decision maker LEI is not valid).
- TR files are processed every day 11AM–11PM. The system will receive TR files the other hours of the day, but the files are not processed during that time.
- Please note that it is our recommendation that reporting for trading date T occur first on T+1.
- We recommend that the date in the file name (TR_XXXXXXXXXXXXXXXXXXXX_XX_2018MMDD_XXXX) match the most recent trading date in the file.
- Empty files do not need to be submitted on transaction-free days (i.e. days without any transactions to report).
In order to be able to report transactions in accordance with MiFID II and MiFIR, both the submitting entity and legal entities on whose behalf a transaction has been executed must have an LEI code.
Application to open an account for the production environment
In order to access the TRS 2 system's production environment, firms must send an authorisation application form to FI. Instructions for how to fill in the form are available below for each type of form. To speed up the handling process, scan the completed application form and email it to email@example.com. Then send the original to Finansinspektionen, Box 7821, 103 97 Stockholm Sweden.
Firms reporting their own transactions
The following form should only be used by firms intending to file transaction reports in the TRS 2 system directly from their own IT systems. If the transaction reporting will be filed by an approved reporting mechanism (ARM), an authorisation application form does not need to be sent to FI. It is the ARM reporting on behalf of the firm that must apply to open an account.
Application for authorisation for TRS 2 reporting
Approved Reporting Mechanisms
Approved reporting mechanisms (ARM) intending to report on behalf of one or multiple firms subject to the reporting obligation should use the following form to apply to open an account:
Application for authorisation for TRS 2 reporting, Approved Reporting Mechanism, ARM
Operators of trading venues must report according to Article 26(5) of MiFIR
Operators of trading venues that are subject to the reporting obligation in accordance with Article 26(5) of MiFIR should use the following form to apply to open an account:
Authorisation Application TRS2 Reporting, Operators of trading venues subject to file reports under Article 26(5) of MiFIR (Only available in Swedish at present as "Behörighetsanmälan TRS2-rapportering, marknadsoperatör rapporteringsskyldig enligt art.26.5 i Mifir")
FI sends log-in information by certified mail to the contact person specified in the authorisation application. The letter also contains additional information needed to connect to the TRS 2 system.
It is only possible to connect to the TRS 2 system using an FTP client that supports SFTP. NOTE: There is no online interface for reporting transactions in accordance with MiFID II/MiFIR.
FI sends a letter with the IP address to connect to the system and log-in information to Submitting Entities. See Log-in information. Go to Port 22.
By connecting to Port 22, FI's server automatically encrypts the connection using a pre-installed certificate. When connecting, a window pops up asking if you trust the host key at FI. Click OK to accept the key and encrypt the channel.
The letter containing the log-in information also contains information about the folder structure on FI's SFTP server. Transaction files (TR files) to be sent to FI are placed in the Outgoing folder. Feedback files (FF and FD files) are downloaded from the Incoming folder.
Reports of transactions in financial instruments in accordance with MiFID II/MiFIR are filed in accordance with the technical specifications from the European Securities and Markets Authority (ESMA).
The information that must be filed in transaction reports (i.e. how the fields should be filled in) is described in Annex 1, Table 2.
ESMA's technical instructions
File Validation Rules
Content Validation Rules
XML schema (zip file)
Planned service disruption
FI occasionally needs to close the TRS 2 system for maintenance or to rectify problems or other disruptions.
Planned service disruptions occur
- as needed, 5:00 pm–23:59 pm every Wednesday.
Responsibility of rapporteurs during service disruptions
When the TRS 2 system is closed, it is not possible to report transactions via the system. Persons responsible for reporting must ensure that the information is stored during the service disruption and submitted as soon as the TRS 2 system opens again.
During service disruptions, it is particularly important for persons responsible for reporting to ensure that all information has been reported.
Report problems with the TRS 2 system to firstname.lastname@example.org.
Notifications about service disruptions
Subscribe to updates related to reporting to FI. Check the box for "Reporting" under "Subscribe to fi.se" on the Subscribe page.
The TRS 2 system uses reference data from ESMA.