ESMA Transparency Manual: UPIs for OTC Derivatives and Tick-Size Rules

On 15 October 2026 ESMA published a new version of its Manual on pre-trade and post-trade transparency under MiFID II/MiFIR (ESMA74-2134169708-6870). The ESMA transparency manual now gives field-level guidance on how trading venues, approved publication arrangements (APAs) and the future OTC derivatives consolidated tape should identify the OTC derivatives caught by Article 8a(2) of MiFIR: a unique product identifier (UPI) under ISO 4914 in the instrument identification field, eleven descriptive fields built on Commission Delegated Regulation (EU) 2025/1003, and two new date fields. The same release moves the tick-size Q&As into the manual, sets out when trading venues and national competent authorities (NCAs) may intervene on a tick size or on the most relevant market, and deletes the equity table that listed which transactions go to ESMA’s Financial Instruments Transparency System (FITRS).

The OTC derivatives guidance arrives with a status warning. ESMA’s announcement says it should be considered a draft until the related technical standards, RTS 2 and the RTS on consolidated tape provider (CTP) input/output data, enter into force. The manual’s own text sets the trigger at publication of the Commission’s amending regulation in the Official Journal. That regulation, adopted by the Commission on 13 July 2026, applies most of its amendments, including those to RTS 2 and to the CTP input/output rules, from 1 March 2027, while CDR 2025/1003 has applied since 1 September 2026. Build teams therefore hold a specification they can map against, a legal text that is not yet in the Official Journal, and two dates that do not line up.

The tick-size answers are different in kind. They carry no draft caveat, they narrow what a venue or an NCA can still change once an instrument’s four-week or annual calculations apply, and they fix a default liquidity band for shares whose average daily number of transactions (ADNT) has not been published.

Related reading: OTC Derivatives Consolidated Tape: ESMA Names the First Provider

The dates that frame the October update

The table separates what is already law from what is still pending.

What the 15 October ESMA transparency manual changes

The manual’s summary table of updates lists three entries dated 15 October 2026. Each touches a different part of the document, and each has a different status.

The manual is a soft-law Level 3 tool. ESMA issues it under Article 29(2) of the ESMA Regulation, Regulation (EU) No 1095/2010, and paragraph 2 of the manual states that it neither intends to provide an interpretation of EU law nor contains supervisory elements. Its weight comes from convergence: it brings ESMA’s guidance on post-trade transparency and the transparency calculations, including Q&As moved over from ESMA’s transparency Q&A document, into one text.

Spotting what moved takes some care. The PDF still sits under a 2023-07 folder in its web address, so a document tracker that keys on the URL will not register a new version. The reliable markers are the cover date, the summary table of updates in Section 2, and the “[Last update on: 15/10/2026]” stamps on individual rows. In Table 86, older Q&As carried over into the manual appear in red, and new or amended text is highlighted in yellow; deleted wording is struck through.

Which OTC derivatives Article 8a(2) brings into scope

The new identifiers apply only to the OTC derivatives referred to in Article 8a(2) of MiFIR, a provision inserted by the MiFIR review, Regulation (EU) 2024/791. All of them are denominated in EUR, JPY, USD or GBP and centrally cleared, and they fall under three points:

• point (a): derivatives subject to the clearing obligation under Title II of EMIR, with a contractually agreed tenor of 1, 2, 3, 5, 7, 10, 12, 15, 20, 25 or 30 years where they are interest rate derivatives;
• point (b): single-name credit default swaps referencing a global systemically important bank (G-SIB);
• point (c): credit default swaps referencing an index comprising G-SIBs.

Section 4.1.2 of the manual presents point (a) as two bullets, one for interest rate derivatives and one for credit derivatives subject to the clearing obligation.

Exchange-traded derivatives remain in the transparency regime, and field 2 of Table 13 keeps the ISIN for every other instrument in transparency scope. A centrally cleared OTC euro swap with a four-year tenor falls outside the tenor list and therefore outside Article 8a(2); under Section 4.1.2 of the manual, post-trade transparency for derivatives covers only exchange-traded derivatives and the Article 8a(2) OTC derivatives, so that swap has no post-trade report in which to carry either a UPI or an ISIN. Because point (a) runs through the EMIR clearing obligation, a change to that obligation’s perimeter moves the transparency perimeter with it; our article on EMIR 3 clearing obligation reform covers the current thresholds.

Two scope points need settling before any mapping starts. The first is “centrally cleared”. In its June 2025 final report on RTS 22 and RTS 24, ESMA read Article 8a(2), point (a), as covering trades cleared voluntarily and trades for which there is an intention to clear, noting that EMIR’s only definition is clearing through a CCP. That reading was given in the transaction reporting context, and the manual does not restate it for transparency.

The second is asset class. CDR 2025/1003 defines its Table 1 attributes for OTC interest rate swaps only. For credit default swaps, Article 1(2) of the regulation adds the UPI and nothing else, and the manual gives formats for fields 2c to 2m only “for IR derivatives in scope of Article 8a(2)”. The Commission’s 13 July 2026 amendment to RTS 2 defines effective-date field 2a and expiry-date field 2b for OTC interest rate derivatives only, so no date field applies to credit default swaps; the manual’s draft rows should be mapped with that distinction preserved.

Table 13 field by field: the UPI and the CDR 2025/1003 attributes

Table 13 is ESMA’s guidance on the common fields of Table 2 of Annex II of RTS 2 (Commission Delegated Regulation (EU) 2017/583), the post-trade report that venues and APAs publish. The 15 October version inserts thirteen rows between the instrument identifier and the price field. The values below are the formats ESMA gives for interest rate derivatives in scope of Article 8a(2).

Some rows carry conditions that the value lists do not show.

• Roll convention depends on standard business terms. When field 2l is TRUE, field 2m takes IMMX or STDX; when 2l is FALSE, field 2m is not populated at all.
• The INDEX list for field 2h is the one in field 15 of Table 2 of the Annex to Commission Implementing Regulation (EU) 2022/1860, the EMIR reporting ITS. Rates outside that list go in as free text of up to 25 characters. For the wider EMIR field set, see our EMIR reporting requirements guide.
• Field 2i exists because CDR 2025/1003 describes the underlying reference rate as identifying both the rate and its term, and ESMA gives the term its own row (footnote 28 of the manual).

Notional currency appears in Table 1 of the CDR 2025/1003 Annex but gets no new row; Table 2 of Annex II of RTS 2 already carries it as field 11.

Standard business terms need their own reference data. Table 2 of the CDR 2025/1003 Annex sets the standard terms for each reference rate it covers, and the manual’s footnote 29 records that it does not specify them for USD-FedFunds. ESMA’s Table 13a supplies the FedFunds terms, so the TRUE or FALSE call for a FedFunds swap rests on an ESMA table that sits outside the delegated regulation.

The consolidated tape side: Tables 106a and 111a

Article 22a of MiFIR identifies trading venues and APAs as CTP data contributors. ESMA Q&A 2828, published on 1 April 2026, clarifies that instrument-status and trading-system regulatory data are normally supplied by trading venues, because APAs do not operate trading systems. An APA transmits that regulatory data where it acts as a service provider on behalf of a trading venue. Its ordinary contribution is post-trade transaction data. The Commission’s 13 July 2026 regulation would write the content of that feed into CDR 2025/1155, the RTS on input and output data of consolidated tapes. Under the Commission’s adopted but not yet applicable July 2026 amendment, Article 3(2) would insert Article 6a into CDR 2025/1155, specifying the OTC derivatives core market data in Table 10 to be transmitted per transaction and the regulatory data in Tables 8 and 9 to be transmitted per financial instrument and trading system respectively, subject to the applicable input/output designations. Article 3(4) would insert Article 8a, specifying the corresponding CTP dissemination requirements. These provisions are scheduled to apply from 1 March 2027, subject to the amending regulation entering into force.

The manual mirrors the RTS 2 rows in two new tables. Table 106a in Section 7.1.3 covers Table 8 regulatory data per instrument, with the UPI in field 1 and the descriptive attributes as fields 1a to 1k. Table 111a in Section 7.2.4 covers Table 10 core market data, with the UPI in field 2, effective and expiry date in fields 3 and 4, and the attributes in fields 4a to 4k. The content matches Table 13 while the numbering does not. The labels 1a to 1k and 4a to 4k are the manual’s explanatory attribute subfields; the Commission’s CTP annex numbers Table 8 fields 1 to 7, Table 9 fields 1 to 5 and Table 10 fields 1 to 22, and carries no fields 1a to 1k or 4a to 4k, so the manual’s labels and the legal CTP fields need separate mappings.

The same Article 3 of the amending regulation also removes exchange-traded commodities and exchange-traded notes from the input and output data of the bond consolidated tape, a change that does not appear in the manual’s 15 October list of updates.

Draft guidance, a 2026 regulation and a 2027 application date

The timing needs the closest reading, because the sources give different dates:

• CDR 2025/1003, Article 1: from 1 September 2026, its identifying reference data “shall be used” for the transparency requirements in Articles 8a(2), 10 and 21 of MiFIR.
• The amending regulation, C(2026) 4777 final, dated 13 July 2026: Articles 1, 2 and 3(1) to (5), which carry the RTS 2, package-order and CTP data changes, apply from 1 March 2027. The regulation enters into force on the twentieth day after publication in the Official Journal.
• ESMA, 15 October 2026: the OTC identifying reference data guidance is a draft. The news item ties that status to the entry into force of RTS 2 and the CTP input/output RTS; the manual ties it to OJ publication of the amending regulation.

CDR 2025/1003 specifies 1 September 2026 for the use of OTC identifying reference data, while the Commission’s July 2026 amendments specify 1 March 2027 for the relevant RTS 2 and CTP data changes. ESMA addressed that mismatch in its MiFIR Review final report on derivatives transparency of 15 December 2025 (ESMA74-276584410-10987, paragraphs 44 and 45): it believed the policy intention of CDR 2025/1003 was not to apply the new identifying reference data under the old transparency regime, and said the two should apply from the same date, 1 March 2027. That is ESMA’s stated belief in a report to the Commission, not a rule in CDR 2025/1003, and the manual sections updated on 15 October do not address the intervening period. The open point for each reporting entity is what its home NCA expects in field 2 for Article 8a(2) trades before 1 March 2027.

Two smaller items belong in the change log. The manual dates the Commission’s adoption to 13 July 2025; the Commission document is dated 13 July 2026 and the Council recorded its receipt that day, so the 2025 reference looks like a slip. The Commission’s July 2026 RTS 2 amendment does not introduce separate post-trade reporting fields for contractual term or effective date offset.

Tick-size intervention: what can still change after the first four weeks

The tick-size regime comes from Article 49 of MiFID II, which requires regulated markets to adopt tick-size regimes in shares, depositary receipts, ETFs and similar instruments, and from RTS 11, Commission Delegated Regulation (EU) 2017/588, which sets minimum tick sizes by liquidity and price level. The liquidity band follows the ADNT on the most relevant market in terms of liquidity (MRMTL), measured in three stages: estimates when the instrument is first admitted or first traded, a calculation on the first four weeks of trading (FFWK), and annual calculations. The new Table 86 answers depend on the stage.

The question ESMA answers is whether a venue or an NCA can manually allow a different tick size where the mandated minimum is shown to harm liquidity. During estimates, the change “can always be granted”. During the estimates stage, any permitted request for a different tick size must be assessed against the actual effective date of the first-four-weeks ADNT result. Article 3(6) of RTS 11 requires that result to be calculated and published no later than six weeks after the first trading day, but the corresponding tick size applies from publication. Six weeks is therefore the latest publication deadline, not an automatic effective date. The manual’s answer glosses the FFWK effective point as six calendar weeks after the Field 11 date of RTS 23, and should be read against that Article.

Once FFWK or annual figures apply, the answer splits. For shares with an ISIN issued outside the EEA, or with an EEA ISIN but traded on a third-country venue in the local or another non-EEA currency, where the MRMTL is in a third country, regulated markets may provide for the same tick size as that venue. That limb restates the second subparagraph of Article 49(2) of MiFID II. ESMA’s answer adds a second limb that the Level 1 text does not contain: a different tick size in the case of a corporate event. For every other share and depositary receipt, the ADNT on the MRMTL is fixed by the first four weeks of trading and cannot change unless a corporate action has occurred. A liquidity argument on its own does not reopen the band.

The MRMTL answer, which covers ETFs, certificates and other equity-like instruments as well, follows the same staging. ESMA allows a correction during estimates and FFWK under Article 4(4) of RTS 1 and names the typical cause: a venue reports the wrong first-admission or first-trade date in Field 11, the MRMTL comes out wrong, and the NCA of that venue has to get Field 11 corrected before the MRMTL can be fixed. After annual calculations, the MRMTL is the output of volumes recorded on each venue and is closed to manual change.

ADNT ownership, corporate actions and the default band

Three of the amended Table 86 answers deal with who produces the ADNT and what applies before it exists.

Responsibility sits with the NCA of the MRMTL as identified for transaction reporting purposes. For multi-listed instruments, Article 16 of RTS 22, Commission Delegated Regulation (EU) 2017/590, sets the criteria and procedure. For new instruments, the relevant market is the Member State where a request for admission to trading was first made or where the instrument was first traded, and that NCA publishes the estimates and preliminary calculations under Article 3(5) and (6) of RTS 11. The amended answer also deletes a sentence on publication arrangements: the old text said the ADNT of an NCA with an agreement with ESMA was published centrally on ESMA’s website, and other NCAs’ figures on a best-effort basis.

Corporate actions get a sharper answer. Any corporate action that the relevant NCA expects to change the average daily number of trades materially can start a recalculation under Article 4 of RTS 11, both for a new ISIN, which starts on estimates, and for the old ISIN, which in most cases sits on annual calculations. ESMA’s examples are share buybacks and share issuance that would otherwise leave the instrument trading in a band that is not optimal.

The default band used to be a pointer to Q&A 8 of Section 4 of ESMA70-872942901-38 (Q&A 1630 in ESMA’s Q&A tool); the answer text is now in the manual. Where the ADNT for an instrument admitted to trading or traded in the EU is not available, trading venues assign the highest liquidity band, the band for an ADNT of 9,000 or more, until ESMA or the relevant NCA publishes the figure. In that answer, ADNTs published to replace the default apply the day after their publication, so a share on the default band can move to another band, and another tick size, the day after its figure appears. Other publications follow their own dates: annual results apply from the first Monday of April, and an adjusted ADNT under Article 3(10) of RTS 11 applies from the second calendar day after publication.

FITRS after the deletion of Table 98

The third change removes guidance. Table 98 set out, transaction type by transaction type, which equity transactions trading venues and APAs reported to FITRS for each transparency parameter: liquidity, large in scale, MRMTL, tick size and standard market size. The whole table is now struck through, and Section 5.5.2 carries a 15 October 2026 stamp.

The deletion is consistent with the wind-down ESMA already set out in Section 3.2.2. Collection of quantitative data for equity and equity-like transparency calculations was discontinued from 1 January 2026, and bond calculations stopped from the application date of the revised RTS 2 on 2 March 2026. Derivatives are the exception. Their calculations continue until the amended RTS 2 provisions covering derivatives start applying, and Table 99, the scope table for derivatives transactions reported to FITRS, stays in place with a note that it no longer applies to bonds, structured finance products and emission allowances from 2 March 2026.

Section 5.5 still says that Tables 98 and 99 analyse which transactions are reported to FITRS. That cross-reference creates no obligation, but a control library that cites Table 98 now points to deleted guidance.

What venues, APAs and investment firms should check now

The update lands differently on each role. The table below lists the manual change and the check it implies.

Responsibility for publishing an OTC trade follows Article 21a of MiFIR. Where only one party is a designated publishing entity (DPE) for the class of instrument, that party makes the trade public through an APA; where neither or both are, the seller does. Our note on MiFIR DPE notification walks through how one NCA handles the designation request.

The UPI change stays on the transparency side. Article 26 transaction reports, covered in our MiFIR transaction reporting guide, keep their own identifier rules under RTS 22, so a firm that publishes and reports the same swap can end up carrying a UPI in one stream and its existing identifier logic in the other.

Frequently Asked Questions

Does the UPI replace the instrument identifier in MiFIR Article 26 transaction reports?

The 15 October update covers post-trade transparency reports under RTS 2 and the data sent to the OTC derivatives consolidated tape. Transaction reports follow RTS 22, and ESMA’s June 2025 final report on RTS 22 and RTS 24 contained no draft amendments to either RTS, because ESMA chose to reduce the burden on market participants and focus on a more comprehensive review of regulatory reporting. It therefore proposed no amendment making the UPI the Article 26 transaction-reporting identifier.

What standard business terms does Table 13a set for USD-FedFunds swaps?

Modified Following business day adjustment; Act/360 day count on both the fixed and floating legs; annual payment frequency on both legs; a fixing lag of 0 business days; USNY fixing and payment calendars; no additional payments. The table shows two variants side by side: a standard roll with a two-business-day effective date offset, and an IMM roll with the offset shown as “Next”.

An exchange-traded interest rate future is in transparency scope. What goes in field 2?

The ISIN. Table 13 keeps {ISIN} for every instrument other than the Article 8a(2) OTC derivatives, and the formats ESMA gives for fields 2c to 2m are written for in-scope OTC interest rate derivatives.

A share is admitted to trading on two EU venues at the same time. Which NCA’s figure sets the tick-size band?

The 2017 answer kept in Table 86 says ESMA’s website always displays one NCA as the NCA of the most relevant market in terms of liquidity, referring to Article 26 of MiFIR. For a simultaneous dual listing, that single NCA is the one whose ADNT drives the band.

What happens to orders resting on the book when an instrument moves to a larger minimum tick size?

Trading venues decide whether such orders are cancelled or amended, and they are responsible for disclosing those rules. Orders submitted after the new tick size comes into force have to respect it. This 2016 answer is unchanged.

Do minimum tick sizes apply to negotiated trades, reference-price systems and large mid-point orders?

The regime applies to all orders submitted to trading venues, including limit orders resting on a book and orders held in an order management system, and to quotes as well as orders. It does not apply to transactions in systems matching orders on a reference price under Article 4(1)(a) of MiFIR, to negotiated transactions under Article 4(1)(b), or to large-in-scale orders matched at the mid-point of the bid and offer, which Article 49(1) of MiFID II expressly permits.

The same share trades in EUR on one venue and in SEK on another. Does the band differ by currency?

ESMA’s 2016 answer, kept in Table 86, says the same liquidity band applies irrespective of the quotation currency, relying on Recital 8 of RTS 11, under which the tick size regime applies equally regardless of the currency of the financial instrument. The instrument stays in its band until a periodic or ad hoc review by the relevant NCA or ESMA assigns a different one.

Related Articles

• OTC Derivatives Consolidated Tape: ESMA Names the First Provider: ESMA’s selection of the first OTC derivatives CTP and what it means for data contributors.
• MiFIR Transaction Reporting: Complete Guide to Article 26 Compliance: the Article 26 regime that runs alongside post-trade transparency.
• MiFIR DPE Notification: Luxembourg’s Publishing Entity Filing: how a firm becomes a designated publishing entity and what that changes for OTC trade publication.
• EMIR Reporting Requirements: What You File, When, and How: the EMIR reporting fields, including the reference rate list reused for field 2h.
• Transaction Reporting Simplification: ESMA’s EUR 1bn Plan: ESMA’s wider plan for EMIR, MiFIR and SFTR reporting.

Key Takeaways

• ESMA’s 15 October 2026 announcement states that the OTC identifying-reference-data guidance should be considered draft until the related RTS 2 and CTP input/output standards enter into force. Under Article 5 of the Commission’s 13 July 2026 amendment, entry into force occurs on the twentieth day following publication in the Official Journal. Articles 1, 2 and 3(1) to (5) have the separate application date of 1 March 2027.
• Plan go-live for 1 March 2027, the application date of the RTS 2 and CTP data amendments, and record the home NCA’s expectation for the period since 1 September 2026.
• Maintain separate mappings for the draft manual’s explanatory attribute subfields and the legally specified CTP data fields. The Commission’s July 2026 CTP annex defines Table 8 fields 1 to 7 for instrument-level regulatory data, Table 9 fields 1 to 5 for trading-system regulatory data and Table 10 fields 1 to 22 for transaction-level core market data. The manual’s 1a to 1k and 4a to 4k attribute labels must not be mistaken for additional numbered fields in the Commission’s CTP annex.
• For an estimates-stage intervention, use the actual date on which the first-four-weeks ADNT result becomes effective; it may precede the six-week publication deadline in Article 3(6) of RTS 11. The separate corporate-action and third-country-share provisions must also be considered where applicable.
• Reference-data controls must distinguish the type of ADNT publication. Where an unavailable ADNT is replaced, ESMA’s default-band Q&A specifies application from the day after publication. Annual ADNT results follow their scheduled application date: the 2026 annual calculations apply from 6 April 2026 and the next annual calculations from 5 April 2027. Adjusted ADNTs under RTS 11 Article 3(10) apply from the second calendar day after publication.
• Legacy collection rules for equity transaction-level transparency calculations can be reviewed for retirement, because the October manual deletes Table 98. This does not end the use of FITRS equity transparency results: the manual’s Table 85 still sets annual ADNT and MRMTL application dates. Derivatives quantitative data collection continues pending application of the revised derivatives RTS 2 provisions.

Sources and References

• ESMA, “ESMA updates its manual on transparency with new guidance for OTC derivatives and tick-size regime” (15 October 2026): esma.europa.eu
• ESMA, Manual on pre-trade and post-trade transparency under MiFID II/MiFIR, ESMA74-2134169708-6870 (15 October 2026): PDF
• Regulation (EU) No 600/2014 (MiFIR): EUR-Lex
• Regulation (EU) 2024/791 (MiFIR review), including Articles 8a, 21a and 22a: EUR-Lex
• Directive 2014/65/EU (MiFID II), consolidated text of 6 June 2026, Article 49: EUR-Lex
• Commission Delegated Regulation (EU) 2025/1003 on OTC derivatives identifying reference data: EUR-Lex
• Commission Delegated Regulation C(2026) 4777 final of 13 July 2026 amending Delegated Regulations (EU) 2017/583, 2017/2194 and 2025/1155 and correcting 2017/587, transmitted as Council document 11909/26: Council register
• Commission Delegated Regulation (EU) 2017/583 (RTS 2): EUR-Lex
• Commission Delegated Regulation (EU) 2025/1155 (input and output data of consolidated tapes): EUR-Lex
• Commission Delegated Regulation (EU) 2017/587 (RTS 1): EUR-Lex
• Commission Delegated Regulation (EU) 2017/588 (RTS 11, tick sizes): EUR-Lex
• Commission Delegated Regulation (EU) 2017/590 (RTS 22): EUR-Lex
• Commission Implementing Regulation (EU) 2022/1860 (EMIR reporting ITS): EUR-Lex
• Regulation (EU) No 1095/2010 (ESMA Regulation), Article 29(2): EUR-Lex
• ESMA, Final Report on RTS 22 and RTS 24, ESMA12-2121844265-4779 (June 2025): PDF
• ESMA, MiFIR Review Final Report on transparency for derivatives, package orders and input/output data for the derivatives consolidated tape, ESMA74-276584410-10987 (15 December 2025): PDF

Next checkpoint: the Official Journal, then 1 March 2027

The event to watch is publication of the Commission’s 13 July 2026 regulation in the Official Journal. Official Journal publication starts the twenty-day period before the amending regulation enters into force. ESMA’s 15 October announcement describes the guidance as draft until the related RTS enter into force, on the twentieth day after Official Journal publication; the manual itself ties the draft status to publication of the amending regulation in the Official Journal, and the sections updated on 15 October do not reconcile the two wordings. The artifact to have ready by then is a tested field map from trade capture to rows 2 to 2m of Table 13 and to CTP Tables 8 and 10, built for the 1 March 2027 application date.

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