What does daylight saving mean for regulatory reporting?
On 31 March, in the early hours of the morning, clocks across the UK and the majority of mainland Europe will go forward an hour. Since Europe spans several time zones, the switch will occur at different local times.
Whilst you may need to adjust the clocks at home or spend another six months with different times on the microwave and oven, please remember that the time fields for UK & EU MiFIR trade and transaction reporting and UK & EU EMIR trade reporting should continue to be populated in Coordinated Universal Time (UTC).
Trade time is of significant importance to regulators. As we have highlighted before, UK and EU NCAs are unlikely to be sympathetic if you make errors following these time transitions. The UK’s FCA has warned firms of such mistakes for many years:
“The time when the transaction was executed should be reported in Coordinated Universal Time (UTC). We continue to see errors in transaction reports when UK clocks transition to and from British Summer Time, as well as errors driven by inaccurate clock synchronisation. Firms should have arrangements in place to ensure consistent and accurate reporting of trading date and time.” Market Watch 59.
The CSSF in Luxembourg has also commented as to the importance of this field:
“In the context of data quality tests performed on transaction reports, the CSSF identified that in several transaction reports the time indicated in field 28 “Trading date time” was the local time instead of UTC. Investment Firms have been informed that, within the framework of the transaction reporting obligation, dates and times shall always be reported in UTC.”
- For more details or a discussion with one of our regulatory experts, please contact us.
