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In February 2019, we announced that if the UK leaves the EU without an implementation period (a no-deal scenario), firms and trading venues should make reasonable steps to comply with any requirements they have to submit instrument reference data from exit day.
We have built FCA FIRDS for firms and trading venues to submit this data. In a no-deal scenario, FCA FIRDS will replace the ESMA FIRDS system in the UK
Testing FCA FIRDS publishing solution
From 14 March 2019, firms will be able to test FCA FIRDS’s publishing solution, which enables firms to download full and delta reference files. Firms will need to test using the FCA FIRDS production publishing system (not the FCA FIRDS industry testing publishing system which is currently being restricted as we complete some format and data verification).
To test FCA FIRDS production publishing system, firms should follow the instructions in the FCA Financial Instruments Reference Data System – Instructions on access and download of full and delta reference files.
Firms will be able to download FCA FIRDS delta files and compare them to the files from ESMA FIRDS.
FCA FIRDS will check that the reference data for each instrument identifier is consistent with the reference data in the relevant master record for that identifier. FCA FIRDS master record is determined by a logic that assigns priority to submissions from UK trading venues rather than the existing ESMA approach. As a result, firms may notice divergence in the published data between FCA FIRDS and ESMA FIRDS.
FCA FIRDS is open before Brexit for testing purposes only. ESMA FIRDS is the primary source for files until the exit day. This means ESMA DATINS and FULINS files should not be substituted with FCA FIRDS DATINS and FULINS files until we advise you to do so. Read FCA FIRDS and transaction reporting for further information.
Submissions to FCA FIRDS
Before Brexit, the FCA FIRDS production system will have a one-way connection to our MDP system. Data will flow into FCA FIRDS, but it will not generate feedback to firms. This allows daily Trading Venue Instrument Reference Data (TV IRD) files to be delivered and processed by ESMA as normal. So, for firms there will be no change to the origin of the feedback files.