Question 5.1.11

Separation of more than one market participant or market participant codes (inside information).

Field 17 allows to indicate more than one market participant. It is not clear how different names shall be separated if the unit concerned is owned by various market participants.

Field 18 refers to the market participant code. We were of the opinion that various names in field 17 would have to be accompanied by the same number of market participant codes in field 18. However, the number of eligible character leaves it open whether this is really meant.

There might be owners of a unit who do not have a market participant code such as pension funds. It is not clear who to indicate that.

We suggest to use a semicolon “;” in fields 17 and 18 for the separation of different market participants and different market participant codes. If a market participant has no code we recommend to use “NA”.

This makes sure that there is always the same number of owners and respective codes or respective “NA” and helps to cross-reference publications for any market participant if needed.

Answer: Fields 17 and 18 are unbounded in the XML schema meaning that you can repeat multiple values (multiple MPs’ names and EIC codes) inside the schema. The number of Market Participants in field (17) ‘Market Participant’ has to be the same as the number of EIC codes provided in field (18) ‘Market Participant code’. The obligation to publish inside information rests with the Market Participant. If the unit’s owner is not a Market Participant then it should not be reported in fields (17) and (18).