Following the Authority’s technical remarks about the MiFID II Phase 2 First Round of Testing, the notice on the availability of the MiFID II phase 2 testing portal through the Managed File Transfer solution and the updates on the TREM XML schema version 1.1.0 go-live date, the MFSA would like to add a further update on this matter, particularly providing further information on the go live of XML Schema version 1.1.0.
The Go-live Date
The updated FIRDS reference data and TREM XML Schema are expected to go-live on the 23 of September 2019, around 10 AM, subject to approval by ESMA stakeholders. Only submissions making use of the XML Schema version 1.1.0 will be accepted on and after the go-live date. You might wish to refer to the changes presented in Annex I for FIRDS 3.0.2.
Cut-off date and maintenance window
Readers should note that on the 20 of September 2019, 6 PM, the old schema (FIRDS XSD 1.0.0 and TREM XSD 1.0.3) will become obsolete and replaced with the newer schema. Any submissions made to the Authority following the cut-off date should be made using schema version 1.1.0.
In order to achieve a smooth transition to the new schema, the Authority's systems will be unavailable during a two-day maintenance window, starting on the 20 of September 2019, 6 PM and ending on the 23 of September 2019, 10 AM. Any transaction backlog occurred during the maintenance window must be reported using the new schema, when the systems will be available again, on 23 of September, 10 AM.
During this maintenance window, it will not be possible nor allowed to report files during the maintenance window. Entities will not be able to see their folders, either through the Authority Portal or any Automated resource (SFTP). If a file reported with the old schema reaches the system during the migration period, it will be rejected by the MIFID processor when it goes online with the new schema. Furthermore, a message will be displayed to portal users during the maintenance period.
The Entities are supposed to continue the file sequence and other file name and transaction identification validations that are currently in place. The file name, file sequence and transaction identification restrictions that were lifted in the test platform will be enforced again.
The Authority's systems will become available following the maintenance window, i.e. on the 23 of September 2019, 10 AM. Thereafter, submitting entities are then expected to make submissions using the new schema. Transactions marked as Pending , reported prior to the cut-off date will have their respective acceptance or rejection feedback following the new schema. Notwithstanding, Cancellation and Resubmission of transactions that were previously processed by TREMM, must also follow the new schema from the Go-Live date.
Increase of upload size limit
The Authority has increased the file upload size limit from 200 kilobytes to 1 megabyte per file. This increase now allows for around 20,000 transactions to be submitted per file. This change should enable entities to submit more transactions using fewer files.