CSDR9 reporting

According to Article 9(1) of CSDR , settlement internalisers shall report to the competent authorities of their place of establishment on a quarterly basis the aggregated volume and value of all securities transactions that they settle outside securities settlement systems. Competent authorities shall transmit the information received to ESMA and shall inform ESMA of any potential risk resulting from that settlement activity.

See figure 1. Reporting and submission periods

The concept of internalised settlement

The content of the internalised settlement reporting is further specified in the EU regulation. According to Article 1 of the Commission Delegated Regulation (EU) 2017/391 (RTS on internalised settlement)

For the purposes of this Regulation the following definitions apply:

'Internalised settlement instruction’ means an instruction by a client of the settlement internaliser to place at the disposal of the recipient an amount of money or to transfer the title to, or interest in, a security or securities by means of a book entry on a register, or otherwise, which is settled by the settlement internaliser in its own books and not through a securities settlement system.
'Failed internalised settlement instruction’ means non-occurrence of settlement, or partial settlement, of a securities transaction at the date agreed by the parties concerned due to a lack of securities or cash, regardless of the underlying cause.

Reporting obligation

A settlement internaliser established in Finland should be responsible for reporting the settlement that has been internalised in its books only. Internalised settlement can occur at different level of a securities holding chain (global custodians, sub-custodians, etc.) and it should be reported at the level where it takes place. A settlement internaliser should send the information required under Article 9(1) of CSDR even if there is only one transaction per quarter. On the other hand, the reporting obligation continues normally, ie, a reporting entity is obliged to report also when there is nothing to report. The description of electronic reporting provides further details on the so called zero reporting. Entities should report to the FIN-FSA according to Article 9(1) of CSDR as follows:

one report for its activity in the Member State where it is established (including the activity of its branches in that Member State);
separate reports for the activity of its branches per Member State and ETA country;
one report for the activity of its branches in third countries.

See figure 2. Overall process of the data flow

ESMA Guidelines on Internalised Settlement Reporting under Article 9 of CSDR give some examples of reporting under different circumstances.

Commission Delegated Regulation (EU) 2017/391 (RTS on internalised settlement) contains detailed information on the reporting obligation in its recitals (2).

“A settlement internaliser should only report internalised settlements where it has executed a settlement instruction by a client of the settlement internaliser in its own books. A settlement internaliser should not report subsequent alignments of book-entry positions to reflect the settlement of instructions by other entities in the holding chain of securities, as these do not qualify as internalised settlement. Similarly, a settlement internaliser should not report transactions executed on a trading venue and transferred by the trading venue to a central counterparty (CCP) for clearing or to a CSD for settlement.”

Content and format of the reporting

RTS on internalised settlement (EU) 2017/391 specifies the content of the reporting on internalised settlements and Commission Implementing Regulation (EU) 2017/393 (ITS on internalised settlement) lays down the templates and procedures for the reporting and transmission of information on internalised settlements.

The multidimensional CSDR9-reporting includes – among other things, the following data (information on failed settlements will be compiled separately in the same manner):

Type of financial instruments;
Type of transactions (eg purchase or sale of securities, collateral management operations, securities lending or securities borrowing, repo etc.)
Type of client (professional, retail);
Each issuer CSD information.

Issues to be observed in the context of the transmission of a report

Internalised settlement reports will have to be sent to the FIN-FSA’s new reporting system in XML format. More detailed template descriptions can be found in the figures below and the description of electronic reporting.

Figure 3. shows the conceptual schema of the internalised settlement report XSD ja Figure 4. shows the overall structure of the internalised settlement XSD.

All reporting is based on the use of Reporter’s Portal, and login in to the system takes place using of Suomi.fi e-Authentications and the Suomi.fi authorisations service, FIN-FSA guide (pdf).

All changes affecting the reporting obligation, incl. name of person responsible, must be separately notified to FIN-FSA at STTHelpdesk(at)fiva.fi.

Description of electronic reporting (CSDR9 reporting)

A new description of electronic reporting contains the reporting principles (including file naming convention) to be used by the settlement internalisers in order to send the quarterly internalised settlement reporting to the FIN-FSA

In addition, description of machine-language data transmission of XML format ESMA reports of Financial Supervisory Authority’s new reporting system has been published and updated in the beginning of 2024. Description of electronic reporting of XML format reports (ESMA) (pdf).

Figure 5. presents the transaction reporting process applicable to CSDR9-reporting.

CSDR9 description of electronic reporting.This guidance is covering reports for Q4 2023 and onwards.

Reporting instructions - New reporting system

References