The KDPW ARM service - acting as reporting agent to EU supervisory authorities under MIFIR requirements.

On 3 January 2018, KDPW launched its Approved Reporting Mechanism (ARM) . The ARM service consists of sending trade data to the relevant EU supervisory authority relating to transactions executed as part of trading in financial instruments on behalf of entities obliged to report such data under EU Regulation No. 600/2014 (MIFIR). KDPW has been granted an official ARM authorisation from the Polish Financial Supervision Authority.

Business relationship options

KDPW offers different reporting profiles for participants that need to meet their reporting obligations under Article 26(1) of MiFIR:

  • Self-reporting by investment firms under basic participation. A basic participant may be an entity which is an investment firm (within the meaning of Article 4(1)(1) of MiFID).
  • Market operators (referred to in Article 4(1)(18) of MiFID), which are obliged to report to the competent supervisory authority details of transactions in financial instruments entered into by market participants located in a third country.
  • Reporting intermediaries (representatives): entities reporting on behalf of investment firms.

How to become a KDPW ARM participant?

Entities applying for KDPW ARM participant status submit an application to conclude a participation agreement. The ARM Rules outline the procedure for processing the application.

The conclusion of the agreement takes place within 10 working days of the submission of the application, together with required attachments, following official confirmation by a KDPW Board resolution.

Onboarding procedures

Application for participation
Entities applying for ARM participant status submit an application to conclude a participation agreement and obtain ARM participant status using the template available on the KDPW website. Enclosures to the application should be attached either as originals or in the form of a certified or notarised copy. The following enclosures should be submitted by prospective participants, together with their application for ARM services:
  • An up-to-date copy or extract from the relevant commercial register or similar document identifying the applicant*;
  • Copies of powers of attorney and notarised signatures of proxies authorised to represent the applicant - if the right to represent the applicant is not apparent from the extract from the relevant commercial register or similar document;
  • Specimen signatures of persons authorised to represent the applicant, certified in accordance with the applicant’s representation rules, or notarised specimen signatures of these persons*;
  • For applications for the participation status of Representative - a power of attorney to send and receive messages transmitted within the ARM system on behalf of the Basic Participant;
  • Instruction (referred to in § 9(4) of the ARM Rules) concerning the generation of reports from GPW and BondSpot by KDPW (where applicable).
*if, on the date of the application, the entity applying for ARM participant status already holds the status of KDPW participant, KDPW TR participant or Investor Compensation Scheme participant and has already delivered this document to KDPW, these documents only need to be provided if the content of the document needs to be updated.

The conclusion of the agreement takes place within 10 working days of the submission of the application together with the correct set of required attachments. Approval of the status of ARM participant takes the form of a resolution of the KDPW Management Board (resolutions are published on the KDPW website).
Access to the ARM system
U2A communication

For each institution code, including the code to be issued by KDPW in connection with an application to become a participant of the ARM, the default distribution channel for messages sent from the ARM is the user interface (GUI). The ARM GUI is accessed via an account in the access application

A2A communication

If a participant wants to use an automated distribution channel (MQ (ESDK/XRAW)), it should notify KDPW of its intention.
  1. Entities applying for ARM participant status which are existing SWI participants (KDPW direct participants) may use the MQ (ESDK) communication channel and use certificates issued under the SWI Rules if they use the institution code that previously identified them in the depository system to identify them in the ARM IT system.
  2. Entities applying for ARM participant status which are Trade Repository participants may use MQ (XRAW) communication by means of electronic certificates issued under the Trade Repository Rules and do not need to apply for new certificates for users with valid certificates in the Trade Repository.
  3. Entities applying for ARM participant status which are not existing KDPW participants and do not have institution codes on account of other services provided by KDPW should apply for an institution code, which is then indicated in the resolution of the KDPW Management Board approving participation in the ARM system.
Once they have obtained participation status, participants complete an application for an A2A electronic certificate and provide the institution code issued by KDPW. After obtaining the certificate, they can set up MQ (XRAW) communication.

After submitting the application for a certificate (and previously completing the certification form), the participant receives an automatically generated message with an attached certification declaration, which must be completed, signed in accordance with the rules of representation, and sent in its original form to KDPW. Once KDPW approves the application and the declaration, the participant receives an email with links to the certificate(s).
Configuration in the ARM system
KDPW completes the configuration of a participant in the ARM system immediately after the Management Board has adopted a resolution on the conclusion of the ARM system participation agreement.
Application for access
Each participant in the ARM service receives an institution code as its identifier. Information on the institution code is provided in the resolution of the KDPW Management Board granting participation status and confirming the establishment of the contractual relationship. Using the code, a person representing the entity applies for access to the ARM GUI via the access application Each participant is required to appoint an Administrator. The Administrator is given the authority to approve user requests submitted as part of the entity’s participation in the ARM service.

Entities reporting large volumes of reports or expecting an A2A communication, request an electronic certificate based on the obtained institution code. As with access to the GUI, the institution code must be used when requesting an electronic certificate.
System documentation
Participants granted access to the ARM system can submit trade reports. The process follows the system’s functional documentation. This documentation is available to ARM participants and entities granted access to the test environment.

It consists of:
  • ARM system specification,
  • content and formal verification of messages in the ARM system and rules for validating trade details in accordance with MiFIR,
  • message flow diagrams,
  • status flow diagrams,
  • XML message structures.

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Client Support

EMIR Trade Repository
+48 22 537 95 29
SFTR Trade Repository
+48 22 537 95 29
Approved Reporting Mechanism (ARM)
+48 22 537 95 29