Under Article 26(5) of MiFIR Trading Venues have to submit transaction reports in relation to the transactions in financial instruments traded on their platforms which are executed through their systems by Firms that are not subject to MiFIR.

 The Trading Venue has to populate all of the details that the Firm would have to report if it were subject to MiFIR as specified in Table 2 of Annex I to Commission Delegated Regulation (EU) 2017/590, including the designations for investment decision within the Firm and execution within the Firm, waivers and indicators flags and the designation to identify the client, where applicable. Where the Firm is dealing on own account these details should be from the perspective of the Firm. Where the Firm is dealing for a client on a matched principal or ‘any other capacity’ basis the Trading Venue should include the additional details in Fields 8-15 (if the client is buying) or in Fields 17- 24 (if the client is selling) and the short selling indicator for the client and commodity derivative indicator, where relevant. The short selling and commodity derivative indicator should be populated from the perspective of the client. With respect to the identification of the executing Firm (Field 4) and of its client (Field 7 and Field 16) where they are eligible for a LEI, the requirements under Article 5 and 13(3) of Commission Delegated Regulation (EU) 2017/590 and Article 26.6 of MiFIR apply. For clients that are not eligible for a LEI code, the Trading Venue should check that the national ID provided does not contain obvious errors or omissions.