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COBS 11.5A Record keeping: client orders and transactions

23/10/2025R

  1. (1)

     [deleted]

  2. (2)

     This section does not apply to corporate finance business carried on by a firm which is not a MiFID investment firm.

Recording initial orders received from clients

23/10/2025R

(1) A firm must, in relation to every initial order received from a client and in relation to every initial decision to deal taken, immediately record and keep at the disposal of the FCA at least the details set out in COBS 11.5A.4R to the extent they are applicable to the order or decision to deal in question.

(2) Where the details set out in COBS 11.5A.4R are also prescribed in requirements imposed by or under Articles 25 and 26 of Regulation No (EU) 600/2014, these details should be maintained in a consistent way and according to the same standards prescribed in requirements imposed by or under Articles 25 and 26 of Regulation No (EU) 600/2014.

Record keeping in relation to transactions and order processing

23/10/2025R

(1) A firm must, immediately after receiving a client order or making a decision to deal to the extent they are applicable to the order or decision to deal in question, record and keep at the disposal of the FCA at least the details set out in COBS 11.5A.5R.

(2) Where the details set out in COBS 11.5A.5R are also prescribed in requirements imposed by or under Articles 25 and 26 of Regulation No (EU) 600/2014, they must be maintained in a consistent way and according to the same standards prescribed in requirements imposed by or under Articles 25 and 26 of Regulation (EU) No 600/2014.

Minimum details to be recorded in relation to client orders and decisions to deal

23/10/2025R
  1. The minimum details to be recorded in accordance with COBS 11.5A.2R are as follows:
  2. 1. Name and designation of the client
  3. 2. Name and designation of any relevant person acting on behalf of the client
  4. 3. A designation to identify the trader (Trader ID) responsible within the firm for the investment decision
  5. 4. A designation to identify the algorithm (Algo ID) responsible within the firm for the investment decision
  6. 5. B/S indicator
  7. 6. Instrument identification
  8. 7. Unit price and price notation
  9. 8. Price
  10. 9. Price multiplier
  11. 10. Currency 1
  12. 11. Currency 2
  13. 12. Initial quantity and quantity notation
  14. 13. Validity period
  15. 14. Type of the order
  16. 15. Any other details, conditions and particular instructions from the client
  17. 16. The date and exact time of the receipt of the order or the date and exact time of when the decision to deal was made. The exact time must be measured according to the methodology prescribed in MiFID RTS 25.

Minimum details to be recorded in relation to transactions and order processing

23/10/2025R

The minimum details to be recorded in accordance with COBS 11.5A.3R are as follows:

1. Name and designation of the client

2. Name and designation of any relevant person acting on behalf of the client

3. A designation to identify the trader (Trader ID) responsible within the firm for the investment decision

4. A designation to identify the Algo (Ago ID) responsible within the firm for the investment decision

5. Transaction reference number

6. A designation to identify the order (Order ID)

7. The identification code of the order assigned by the trading venue upon receipt of the order

8. A unique identification for each group of aggregated clients' orders (which will be subsequently placed as one block order on a given trading venue). This identification should indicate “aggregated_X” with X representing the number of clients whose orders have been aggregated

9. The segment MIC code of the trading venue to which the order has been submitted

10. The name and other designation of the person to whom the order was transmitted

11. Designation to identify the Seller & the Buyer

12. The trading capacity

13. A designation to identify the Trader (Trader ID) responsible for the execution

14. A designation to identify the Algo (Algo ID) responsible for the execution

15. B/S indicator

16. Instrument identification

17. Ultimate underlying

18. Put/Call identifier

19. Strike price

20. Upfront payment

21. Delivery type

22. Option style

23. Maturity date

24. Unit price and price notation

25. Price

26. Price multiplier

27. Currency 1

28. Currency 2

29. Remaining quantity

30. Modified quantity

31. Executed quantity

32. The date and exact time of submission of the order or decision to deal. The exact time must be measured according to the methodology prescribed in MiFID RTS 25.

33. The date and exact time of any message that is transmitted to and received from the trading venue in relation to any events affecting an order. The exact time must be measured according to the methodology prescribed under MiFID RTS 25 on clock synchronisation.

34. The date and exact time any message that is transmitted to and received from another investment firm in relation to events affecting an order. The exact time must be measured according to the methodology prescribed in MiFID RTS 25.

35. Any message that is transmitted to and received from the trading venue in relation to orders placed by the firm

36. Any other details and conditions that was submitted to and received from another firm in relation with the order

37. Each placed order’s sequences in order to reflect the chronology of every event affecting it, including but not limited to modifications, cancellations and execution

38. Short selling flag

39. SSR exemption flag

40. Waiver flag