Within Europe derivative regulated markets use differing methods to identify derivative contracts. LIFFE for example relies upon a contract code whilst the Borsa Italiana employs the ISIN code.

The original CESR proposal for identifying and reporting exchange traded derivative transactions required the use of ISIN codes as for debt and equity instruments. Following extensive discussions with the industry and representations from interested parties, CESR has now recommended two methods by which derivative transactions can be identified. The method to be used depends on the unique identifier used by the exchange on which the derivate contract trades. If the exchange employs ISINs as a unique identifier then reporting firms are required to submit transaction reports identifying the ISIN code pertaining to the derivative contract which is the subject of the transaction report. Where the exchange employs a code other than the ISIN an alternative instrument identifier ("AII") must be used when submitting transaction reports for derivative contracts executed on that exchange.

CESR has published a list of regulated markets which identifies whether they employ ISIN codes or the AII code.

Transitional provisions for reporting on-exchange derivatives

Reporting ISIN based regulated market derivative transactions

Transactions undertaken on regulated derivative markets that utilise ISINs as the instrument identifier should be reported in the normal manner using the ISIN code.
Where the competent authority for the exchange does not require client side transaction reports we do not require these to be reported to the FSA. We maintain a list of authorities requiring client side transaction reports.

Reporting LIFFE market side transaction reports

We will continue to receive a feed from LIFFE's TRS system of all market transactions in derivatives executed on LIFFE, excluding commodity, interest rate and FOREX derivatives . As such firms that currently place reliance on the reporting undertaken by LIFFE can continue to do so post MiFID.

Reporting client side transactions in LIFFE equity and debt derivatives

LIFFE is a regulated market that utilises the AII code. We are aware that ISINs exist for all LIFFE derivatives (an AII regulated market) in the LSE's Masterfile and many firms use these ISINs when reporting LIFFE transactions. Where firms are able to report LIFFE transactions using an ISIN we ask them to do so.

There is a second voluntary method by which firms may report LIFFE client side transactions and other derivative exchange transactions which are not required to be reported. Transactions meeting this criteria can be reported in the following manner:

  • populate the venue identifier field as if the transaction was in an over the counter derivative (i.e. using XXXX)
  • populate the underlying security code field where the underlying is a single equity or single debt instrument
  • where possible, populate the instrument description field with the contract code for the derivative as assigned by that regulated market.

We ask firms to consider whether they can report derivative transactions in this way,and if not detrimental to other systems, to do so.