AMF Publishes RDT Guide on Procedures for Reporting Transactions under MiFIR

Key Takeaways

• The Autorité des marchés financiers (AMF) has published its RDT Guide on the procedures for reporting transactions under MiFIR.
• The update itself contains only the title and a download link, so its specific requirements cannot be confirmed from the text provided.
• Compliance teams should obtain and review the full guide to assess any effect on transaction reporting processes and controls.

Deep Dive

The Autorité des marchés financiers (AMF) has published its RDT Guide on the procedures for reporting transactions under MiFIR. The update itself contains only the title and a download link, so its specific requirements cannot be confirmed from the text provided. Compliance teams should obtain and review the full guide to assess any effect on transaction reporting processes and controls.

Guidance of this type typically addresses practical matters: who reports and through which channel, file formats and technical specifications, submission timing, handling of rejections and corrections, and expectations on data quality and completeness. Firms may also see clarification on how the AMF interprets reporting obligations in areas such as transaction scope, reference data, and the use of Approved Reporting Mechanisms (ARMs) versus direct reporting. These points are common themes, not confirmed content of this guide.

No timelines or deadlines are stated in the update. The publication date is 2026-09-16, but it is unclear whether the guide introduces new expectations, replaces an earlier version, or consolidates existing practice. Compliance teams should check the document for version history, application dates, and any transitional provisions.

Recommended actions:

(1) download the guide and perform a gap analysis against current transaction reporting policies, procedures, and technical connectivity;

(2) engage reporting vendors, ARMs, and internal technology teams to confirm any required changes to file formats or workflows;

(3) review reconciliation, exception management, and error-correction processes against the guide;

(4) brief senior management and update training where needed; and

(5) log the guidance in the regulatory change inventory, noting any French-specific expectations for entities with AMF reporting obligations.

Although guidance is not legally binding, supervisors often use it as a benchmark in examinations, so deviations can lead to findings. The main exposures are inaccurate, late, or incomplete reports, which can bring supervisory scrutiny, remediation costs, and potential sanctions. Overall impact cannot be rated until the full text is reviewed, but firms with French reporting obligations should treat it as a priority review item.

Source: Autorité des marchés financiers