On the 29 July 2019, ESMA published an updated version of its Q&As on the requirements for submission of reference data under MiFIR, which serve to promote common supervisory approaches and practices in the application of MiFIR and to provide guidance relating to compliance with the reporting provisions of MiFIR.

This relates to reporting obligations for financial instruments without a defined expiry date (such as, Perpetual FX Rolling Spot Futures). The new Q&As aim to provide clarification on how operators are to populate Field 24 (Expiry date) for a financial instrument without a defined expiry date, under RTS 23, if it is mandatory according to the CFI validation rules.

ESMA’s Q&As on MiFIR data reporting can be accessed here.