[ESMA70-1861941480-56] Q&A on MiFIR data reporting

The European Securities and Markets Authority, ESMA, has published an updated version of its Questions and Answers (Q&A) on data reporting under the Market in Financial Instruments Regulation (MiFIR). In this latest version, three Q&As were added to the new section 19 pertaining to the Reporting of Emission Allowances. The affected Q&As are quoted below (tables not included):
Topic „LEI of the issuer“ (p. 13)
New Question 8: What LEI should be used to report in FIRDS the issuer of sovereign bonds issued by an EEA member state? (p. 16)
Answer 8: Reporting entities should refer to the list maintained by GLEIF, available at: https://search.gleif.org/#/search/ and report the LEI pertaining to the sovereign entities.
Topic „Transaction reporting“ (p. 58)
Amended Question 11 (f): Does the concept of an underlying for the purposes of Article 26(2)(b) of MiFIR extend to convertible bonds, reverse convertible bonds and reverse convertible notes? (p. 77)
Answer 11 (f) & (g): Yes. Where a transaction takes place in a convertible bond, reverse convertible bond or reverse convertible note (the main instrument) and the instrument into which the bond can be converted is traded on a trading venue the transaction is reportable under article 26(2)(b). Where a transaction report is made on the basis of the instrument being in scope of 26(2)(b) the underlying instrument into which the main instrument can be converted should be reported in field 47. Where the convertible bond, reverse convertible bond or reverse convertible note is also in scope under 26(2)(a) then the underlying does not need to be populated in the transaction report as only the ISIN of the convertible bond needs to be reported (in field 41).
New Question 14 [(p. 82)]: What ISO 3166-1 country code should trading venues and investment firms use to identify stateless natural persons for the purposes of transaction reports?
Answer 14: When identifying stateless natural persons, trading venues and investment firms should use the ISO 3166 code “ZZ”, followed by a CONCAT code generated in accordance with Article 6(4) of Commission Delegated Regulation (EU) 2017/590 (RTS22).