Nasdaq Implementation Guide Order Record Keeping Version 1.7

Nasdaq Implementation Guide Order Record Keeping Version 1.7

1 Summary of order entry requirements
Under MiFID II Article 25 and RTS 24, trading venues are required to keep a database of all order 
records, for all markets that they operate, for a minimum of five (5) years. Upon request from a 
Competent Authority, the trading venue has to make this data available in a predefined report 
format. 
Much of the information required to populate this database can already be found or derived from 
the current order messages or system events. There is however a number of new fields that 
require input from the member or participant with each new order under MiFID II.
As part of this requirement, Nasdaq will collect data from its members, in order to cover the 
following order record keeping fields:
 Client Identification Code (LEI, National ID, ‘NONE’, ‘AGGR’, or ‘PNAL’)
 Investment decision within firm (National ID or Algorithm ID)
 Execution within firm (National ID, Algorithm ID or ‘NORE’)
 Party Role Qualifier (LEI, National ID or Algorithm ID)
 Direct Electronic Access (True or False)*
 Liquidity provision activity (True or False)
 Order capacity/trading capacity
*Derived from reference data configurations, with option to override in INET.
2 Scope of Order Record Keeping
Order Record Keeping will affect all markets trading on INET and Genium INET.
3 Nasdaq solution
Three of the fields that are introduced may contain sensitive and confidential data, therefore the 
solution that Nasdaq will implement requires members to submit ‘short codes’ on each order. 
These fields are Client identification, Execution decision and Investment Decision. Nasdaq will 
support short codes for the Equity, Equity Derivatives, Commodities and Fixed Income markets.
The short codes will be created by the members, according to what is stated in section 5. 
Nasdaq will not validate short codes upon order entry, but we expect a short code that has been 
used a specific trading date, to be mapped up at the latest by end of day, that very same date. This 
will be done in a separate application, Member Portal, see further information in section 7.

4 Order Entry
There will be updates of current Order Entry fields and introduction of new fields.
Update of current Order Entry field
 Order capacity – ‘AOTC’, ‘DEAL’ or ‘MTCH’. The values currently supported for this field 
will remain as specified for each trading system and trading protocol, but will be 
translated by Nasdaq to the corresponding MiFID II trading capacity value for the purpose 
of Order Record Keeping, as specified in Section 6. This field becomes mandatory to 
populate for all markets in Genium INET. On INET, as per existing functionality, an empty 
field will default to ‘Agent’ (‘AOTC’).
New Order Entry fields
 Party ID (Short code)+ Party Role
o Client Identification Code – Short code corresponding to LEI, National ID, ‘AGGR’
or ‘PNAL’. The field becomes mandatory if Order Capacity is AOTC or MTCH. The 
value ‘NONE’ is valid if Order Capacity is DEAL.
o Execution within Firm – Short code corresponding to National ID or algorithm ID
or ‘NORE’. This field is mandatory.
o Investment Decision within Firm – Short code corresponding to National ID or 
algorithm ID. It is mandatory if Order Capacity is DEAL.
 Party Role Qualifier – field added to further define the Party Role
o LEI (applicable to Client ID only)
o National ID (applicable to all three types of Party Roles)
o Algorithm ID (applicable to Investment Decision and Execution within Firm)

Nasdaq Implementation Guide Order Record Keeping Version 1.7