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pc nid 92536 May 15, 2026 tojuri@vixio.com Finland Financial Supervisory Authority horizon scanning
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Finland's Financial Supervisory Authority Publishes Thematic Assessment on Waiver Indicator Reporting in Trade Reporting

On May 13, 2026, the Financial Supervisory Authority (FSA) published a thematic assessment examining the reporting of waiver indicators in trade reporting by Finnish market participants. The assessment evaluated whether entities correctly and comprehensively reported information on exemptions from pre-trade transparency requirements applied to transactions. The assessment focused on compliance with the Markets in Financial Instruments Regulation (MiFIR) (EU) 600/2014, Article 26, which requires reporting transaction information to competent authorities. Reporting formats and data fields are defined in the Commission Delegated Regulation (EU) 2017/590 (RTS 22) and supplemented by guidance from the European Securities and Markets Authority (ESMA/2016/1452). In Finland, trade reporting obligations apply to investment service providers, including credit institutions and investment firms. The FSA examined Field 61 (Waiver indicator) in RTS 22, which requires reporting whether transactions executed on a trading venue applied exemptions under MiFIR Articles 4 or 9 from pre-trade requirements. The assessment identified significant deficiencies in waiver indicator reporting, particularly regarding Reference Price Waiver (RFPT) reporting on Nasdaq Helsinki's Nordic@Mid system. Key findings included incomplete or absent waiver information despite regulatory requirements, inadequate system controls and validations, and insufficient reconciliation procedures. The FSA noted that some entities determined waiver status solely on Market Identifier Code (MIC) rather than transaction-specific data, which is insufficient as MIC codes cannot distinguish Large in Scale (LIS) exemption situations. The FSA conducted the assessment through a survey of Nasdaq Helsinki's Finnish members and analysis of trade reporting data. The assessment emphasised that entities must ensure accurate and comprehensive waiver reporting, implement adequate system controls, and strengthen content-based validations and reconciliations to verify reporting accuracy and completeness. The FSA will provide individual feedback to participating entities with potential clarification requests and corrective action requirements, and will monitor remedial measures through ongoing supervision using trade reporting data.

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Finland's Financial Supervisory Authority Publishes Thematic Assessment on Waiver Indicators in Transaction Reporting

On May 13, 2026, the Finnish Financial Supervisory Authority (FIN-FSA) published a thematic assessment examining the reporting of waiver indicators in trade reporting by Finnish market participants. The assessment evaluated whether entities correctly and comprehensively reported information on exemptions from pre-trade transparency requirements applied to transactions. The assessment focused on compliance with Article 26 of the Markets in Financial Instruments Regulation (MiFIR), which requires reporting transaction information to competent authorities. In Finland, trade reporting obligations apply to investment service providers, including credit institutions and investment firms. The FIN-FSA examined Field 61 (Waiver indicator) in RTS 22, which requires reporting whether transactions executed on a trading venue were exempt from pre-trade requirements under MiFIR Articles 4 or 9. The assessment identified significant deficiencies in waiver indicator reporting, particularly regarding Reference Price Waiver (RFPT) reporting on Nasdaq Helsinki's Nordic@Mid system. Key findings of the review: Shortcomings in the companies under review's reporting of waiver indicators were found. 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 found to have deficiencies in the recording of waiver information in their systems. Controls, rules-based validations, and reconciliations relating to Field 61 were deficient or non-existent in many places. The assessment emphasised that entities must ensure accurate and comprehensive waiver reporting, implement adequate system controls, and strengthen content-based validations and reconciliations to verify the accuracy and completeness of reporting. The FSA will provide individual feedback to participating entities with potential clarification requests and corrective action requirements, and will monitor remedial measures through ongoing supervision using trade reporting data.