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AFM sets graduated fines for unreported MiFIR transaction-reporting failures

The Dutch policy makes incident detection and voluntary notification central to enforcement. Percentage thresholds mean smaller reporting operations can also fall within its scope.

The AFM has introduced a specific fining policy for substantial MiFIR transaction-reporting failures that firms do not notify voluntarily. Announced on 14 October and effective from 15 October, it gives brokers and reporting providers defined thresholds for this enforcement route.[1][2]

Entities & regulation01

Thresholds for reports due to the AFM

Thresholds for reports due to the AFM
Reporting defectTransaction-count testProportion-of-reports test
Missing or lateMore than 100,000More than 25% over at least two weeks
Incomplete, inaccurate or incorrectly submittedMore than 500,000More than 50% over at least four weeks

The starting fine is €25,000 for a first breach and €50,000 for a repeat within five years. A further repeat returns to the general fining policy. These are starting amounts under the prescribed calculation, with case-specific adjustment and financial capacity still relevant.[1][2]

The proportional test also reaches smaller firms: for example, 30% missing reports over two weeks can qualify even when fewer than 100,000 transactions are involved.[2]

Notification deadlines remain a separate control

The AFM’s incident guidance sets out the notification process independently of these fine thresholds. In its working-day timetable, an incident still unresolved at T+3 must be reported on T+4; transaction reports themselves are due at T+1. Historical incidents discovered later must be reported immediately, as must specified serious incidents. The guidance also calls for internal records and investigation of incidents that are not reported.[3]

This requires the firm to connect three pieces of information: what should have been reported, what the regulator actually received, and when the defect was identified. A reporting vendor’s successful file transmission addresses only part of that chain. The commercial value of reconciliation and exception management lies in finding the discrepancy early enough for the firm to act.

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Sources & further reading

  1. Nieuw boetebeleid voor niet-gemelde tekortkomingen in transactierapportages Autoriteit Financiële Markten · 14 Oct 2026 · Accessed 20 Oct 2026
  2. Boetebeleid AFM voor MiFIR-transactierapportages Autoriteit Financiële Markten · Accessed 20 Oct 2026
  3. Transactierapportages: melden incidenten Autoriteit Financiële Markten · Accessed 20 Oct 2026

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