MiFIR/MAR: AII as an alternative to ISIN and the need to align the timing of the application of the ISIN obligation under MiFIR and MAR

Brussels, 4 March 2016 | ESMA’s current draft of the Regulatory Technical Standard (RTS) 231, inter alia specifying Article 3(1) of the Market in Financial Instrument Regulation (MiFIR), puts forward the obligation that each trading venue shall obtain an International Standards Organisation (ISO) 6166 International Securities Identification Number (ISIN) for each financial instrument. Europex does not agree with this obligation and calls for the reintroduction of Alternative Instrument Identifiers (AIIs) as a better adepted solution. In addition, Europex urges a postponement of the obligation to provide financial instrument reference data under MAR (Article 4) along with the corresponding requirement under MiFIR (Article 27) until 3 January 2018, in line with the more general delay of the application of MiFID II/MiFIR.

Please find the position paper attached.