Thematic review of reporting of waiver indicators in transaction reporting - 2026 - www.finanssivalvonta.fi

Thematic review of reporting of waiver indicators in transaction reporting - 2026 - www.finanssivalvonta.fi Publications and press releases Supervision releases 2026 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 Press releases 2026 2025 2024 2023 2022 2021 News releases 2026 2025 2024 2023 2022 2021 Reporting releases 2026 2025 2024 2023 2022 2021 2020 2019 2018 2017 Market newsletter Market Newsletter 1/2026 Market Newsletter 3/2025 Market Newsletter 2/2025 Market Newsletter 1/2025 Market Newsletter 2/2024 Market Newsletter 1/2024 Market newsletter 4/2023 Market newsletter 3/2023 Market Newsletter 2/2023 Market Newsletter 1/2023 Market newsletter 2/2022 Market newsletter 1/2022 Blogs 2026 2025 2024 2023 2020 Annual reports Annual Report 2025 Director General’s review State of financial markets Supervision Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2025 Strategy Appendices Total 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and environmental risk management in the banking and insurance sectors Sanctions as part of the FIN-FSA’s supervisory work Proactive and predictable supervision Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2023 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Annual Report 2022 Director General’s review State of financial markets Supervision Themes Geopolitical situation accelerated preparation for cyber-attacks in the financial sector Energy crisis shook the derivatives market Year of uncertainty in the virtual currency markets ECB’s climate stress testing and thematic review: banks must consider the impacts of climate change in their operations and risk management Corporate governance safeguards the supervised entity’s operations, capital adequacy and the security of the client’s money and insured benefits Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2022 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Case management Annual Report 2021 Director General’s review State of financial markets Supervision Themes Crypto assets attract investor interests – risks to be reined in through regulation New investors, new sources of information New tools needed to contain household indebtedness Sustainability issues as part of financial market participants’ risk management and disclosure obligations Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2021 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Case management Annual Report 2020 DG’s review State of financial markets Supervision Themes Fast decisions supported banks’ resilient operation in exceptional circumstances Unemployment funds coped through coronavirus pandemic despite record growth in number of applications and claims expenses Digital finance gaining ground – European Commission strategy to accelerate development Risk-based approach is a cornerstone of anti-money laundering and countering terrorist financing Suspicions of market manipulation and abuse of inside information are detected and investigated increasingly effectively Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2020 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Case management Annual Report 2019 DG’s review State of financial markets Supervision Themes Report on means to prevent excessive household indebtedness Management of disability risk by pension insurance companies Green Deal and the supervisory perspective EU banking legislation to complete the Basel III recommendations in preparation Fund liquidity issues Audit committees' activities were assessed Responsible utilisation of data in the financial sector Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Journal Public notices 2026 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 Subscription to electronic publications Subscription to press releases Publications and press releases Publications and press releases Supervision releases 2026 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 Press releases 2026 2025 2024 2023 2022 2021 News releases 2026 2025 2024 2023 2022 2021 Reporting releases 2026 2025 2024 2023 2022 2021 2020 2019 2018 2017 Market newsletter Market Newsletter 1/2026 Market Newsletter 3/2025 Market Newsletter 2/2025 Market Newsletter 1/2025 Market Newsletter 2/2024 Market Newsletter 1/2024 Market newsletter 4/2023 Market newsletter 3/2023 Market Newsletter 2/2023 Market Newsletter 1/2023 Market newsletter 2/2022 Market newsletter 1/2022 Blogs 2026 2025 2024 2023 2020 Annual reports Annual Report 2025 Director General’s review State of financial markets Supervision Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2025 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Annual Report 2024 Director General’s review State of financial markets Supervision Themes Sustainability aspects of the financial sector New supervised entities in AML/CTF supervision Cyber security and scam prevention more important than ever Anniversary of the Single Supervisory Mechanism in banking supervision Governance under scrutiny in the insurance sector Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2024 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Annual Report 2023 Director General’s review State of financial markets Supervision Themes Real estate risks increased as a result of weak economic development and rising interest rates FIN-FSA’s thematic reviews examined the current state of climate and environmental risk management in the banking and insurance sectors Sanctions as part of the FIN-FSA’s supervisory work Proactive and predictable supervision Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2023 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Annual Report 2022 Director General’s review State of financial markets Supervision Themes Geopolitical situation accelerated preparation for cyber-attacks in the financial sector Energy crisis shook the derivatives market Year of uncertainty in the virtual currency markets ECB’s climate stress testing and thematic review: banks must consider the impacts of climate change in their operations and risk management Corporate governance safeguards the supervised entity’s operations, capital adequacy and the security of the client’s money and insured benefits Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2022 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Case management Annual Report 2021 Director General’s review State of financial markets Supervision Themes Crypto assets attract investor interests – risks to be reined in through regulation New investors, new sources of information New tools needed to contain household indebtedness Sustainability issues as part of financial market participants’ risk management and disclosure obligations Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2021 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Case management Annual Report 2020 DG’s review State of financial markets Supervision Themes Fast decisions supported banks’ resilient operation in exceptional circumstances Unemployment funds coped through coronavirus pandemic despite record growth in number of applications and claims expenses Digital finance gaining ground – European Commission strategy to accelerate development Risk-based approach is a cornerstone of anti-money laundering and countering terrorist financing Suspicions of market manipulation and abuse of inside information are detected and investigated increasingly effectively Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Summary of FIN-FSA’s activities in 2020 Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Case management Annual Report 2019 DG’s review State of financial markets Supervision Themes Report on means to prevent excessive household indebtedness Management of disability risk by pension insurance companies Green Deal and the supervisory perspective EU banking legislation to complete the Basel III recommendations in preparation Fund liquidity issues Audit committees' activities were assessed Responsible utilisation of data in the financial sector Management and personnel Board Management Group FIN-FSA Financial Supervisory Authority in brief Strategy Appendices Total number of supervised and other fee-paying entities Expenses and funding Set supervision fees Processing fees Journal Public notices 2026 2025 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 Subscription to electronic publications Subscription to press releases Supervision release 13 May 2026 - 27/2026 Thematic review of reporting of waiver indicators in transaction reporting In 2026, the FIN-FSA conducted a thematic review concerning the reporting of waiver indicators in transaction reporting. The objective of the review was to ascertain the correct and comprehensive disclosure in transaction reporting whether any waiver concerning pre-trade transparency requirements has been applied to the execution of the transaction. The transaction reporting obligation is based on Regulation (EU) No 600/2014 of the European Parliament and of the Council (hereinafter MiFIR), in particular Article 26 thereof, which requires the reporting of data on transactions to competent authorities. The reporting formats and data fields are defined in Commission Delegated Regulation (EU) 2017/590 (hereinafter RTS 22), and further guidance is provided by ESMA (ESMA/2016/1452). In Finland, the transaction reporting obligation concerns investment service providers, such as credit institutions and investment firms. The reporting of waiver indicators concerns direct members of trading venues. Field 61 under the Annex to RTS 22 (Waiver indicator) requires reporting of information on whether the transaction was executed under a pre-trade waiver in accordance with Articles 4 and 9 of MiFIR. The field is to be completed only if the transaction was executed on a trading venue applying a waiver, and in such cases only in respect of the market execution itself. As a result of MiFIR Review changes, ESMA will migrate to using transaction reporting data in its transparency and volume cap calculations, which further emphasises the importance of correct reporting of the waiver indicator. In reviews conducted by ESMA, significant deviations have been identified particularly in the reporting of the RFPT reference price waiver, which have been related to incorrect or incomplete completion of Field 61. The thematic review was carried out by means of a survey addressed to Finnish members of Nasdaq Helsinki and by analysing the companies’ transaction reporting data. In the data analysis, particular attention was paid to trades executed in Nasdaq Helsinki’s Nordic@Mid midpoint trading system as well as to negotiated trades, and to whether the information required under field 61 was reported in these situations in accordance with the requirements. Key findings · The data analysis performed by the FIN-FSA and the survey sent to the target companies showed shortcomings in the reporting of waiver indicators by the companies under review. The shortcomings related in particular to the reporting of the RFPT reference price waiver in trades executed in Nasdaq Helsinki’s Nordic@Mid system and to situations where waiver information was not reported at all, even though required by regulation. · Several companies were also found to have deficiencies in the recording of waiver information in their systems. · Controls, rules-based validations and reconciliations relating to Field 61 were in many places deficient or non-existent. Obtaining waiver information The thematic review also examined where companies obtain transaction-specific information on the waivers used and how this information is recorded in the source systems for reporting. Waiver information is transmitted to members via the trading venue’s trade messages. According to the FIN-FSA’s view, companies must have arrangements in place for obtaining and recording transaction-specific waiver information. On the basis of the FIN-FSA’s observations, some companies’ reporting of waiver information in respect of the Nordic@Mid system was inferred solely on the basis of the MIC code. This is not sufficient, as the MIC code does not make it possible to distinguish situations where the trade is subject to the LIS waiver. Reporting of the waiver indicator in field 61 The thematic review identified shortcomings in the coverage of field 61. According to observations made by the FIN-FSA, companies must ensure that the reporting of waiver information is correct and comprehensive and that the data extracted from source systems for reporting is correctly converted into the codes required by RTS 22. Controls and reconciliations On the basis of the responses to the thematic review, quality assurance and supervisory procedures in many cases focused on technical checks (e.g. technical validation of the data set), while substantive checks and reconciliations (field-by-field comparison with own source systems and detection of missing data) were insufficient. According to the FIN-FSA’s view, companies must assess more carefully in which situations waiver information must be reported, evaluate the effectiveness of their rules-based validations (Article 15(1)(d) of RTS 22) and ensure sufficiently comprehensive reconciliations (Article 15(4) of RTS 22) in order to verify the completeness and accuracy of reporting. Follow-up actions of the thematic review The FIN-FSA will send company-specific feedback, including possible requests for clarification and remediation obligations, to the companies that participated in the thematic review. The FIN-FSA will monitor, in its ongoing supervision and with the support of the transaction reporting data received, the corrective measures taken to address the shortcomings identified in the thematic review. For further information, please contact: Heidi Tähtinen, heidi.tahtinen(at)finanssivalvonta.fi Juho Westerlund, juho.westerlund(at)finanssivalvonta.fi Jukka Katajamäki, jukka.katajamaki(at)finanssivalvonta.fi