ANNA responds to ESMA consultation on transaction data reporting and on order book data to be maintained

Brussels, 7th January: ANNA has responded to ESMA’s consultation on the review of RTS 22 transaction data reporting and RTS 24 order book data to be maintained under MiFIR.

ANNA highlighted the complementary roles of the ISIN and DTI. ISINs uniquely identify assets, while DTIs capture the technical attributes of tokens on DLT. Together, they enhance transparency, reduce operational complexity and strengthen data quality in transaction reporting.

ANNA noted that ISINs were revised in 2021 to explicitly cover tokenised instruments and are now supported by additional identifiers such as CFI, FISN and LEI. It also emphasised the progress of its joint work with the Digital Token Identifier Foundation, including the introduction of XT-prefix ISINs for digital assets, managed by Etrading Software Ltd.

Read the ANNA comment letter here.

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