Reporting obligations of investment firms and branches of foreign investment firms

A regulated entity is obliged to start fulfilling its reporting obligations after obtaining an investment firm licence or after completing passporting (in the case of branches of foreign investment firms from the EU) and after registration in the Commercial Register.

Where a licence has been granted or passporting completed and the entity is not ready to commence actual operations, a deferral of reporting obligations may be requested through the contacts listed for each reporting area.

To the extent stipulated by law, entities required to fulfil the reporting obligations of investment firms include:

  1. an investment firm that is a bank,
  2. a foreign bank with a licence for the provision of investment services that provides services in the Czech Republic through a branch,
  3. an investment firm that is not a bank or a branch of a foreign bank,
  4. a foreign entity with a licence for the provision of investment services that is not a bank and that provides services in the Czech Republic through a branch,
  5. a management company and a foreign entity with a licence to operate as a manager that is not comparable with an investment fund, if it manages client assets that include an investment instrument on a discretionary basis under contract (portfolio management),
  6. a management company from another Member State of the European Union that manages client assets that include an investment instrument on a discretionary basis under contract (portfolio management) in the Czech Republic through a branch.

The collection of supervisory and statistical data for the needs of the Czech National Bank and other data users is primarily performed by the SDAT system.

For data acquisition and reporting, the SDAT production environment is used for routine operation, while the test environment is used for testing purposes (link, in Czech only).

Documents for reporting using the SDAT system are available on the CNB website in the section SDAT technical specification (in Czech only). Any changes will be announced in the News section on the main SDAT page of the CNB website (in Czech only).

Contact for registration in the SDAT system and for the resolution of technical difficulties with reporting: sdat@cnb.cz

European legislation on reporting

  • Regulation (EU) 2019/2033 of the European Parliament and of the Council (IFR) of 27 November 2019 on the prudential requirements of investment firms (link)
  • Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU (link)
  • Commission Implementing Regulation (EU) 2021/2284 laying down implementing technical standards for the application of Regulation (EU) 2019/2033 of the European Parliament and of the Council with regard to supervisory reporting and disclosures of investment firms (link)
  • Regulation (EU) No 600/2014 of the European Parliament and of the Council on markets in financial instruments and amending Regulation (EU) No 648/2012 (link)
  • Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities (RTS 22) (link)
  • Directive (EU) 2019/2034 of the European Parliament and of the Council of 27 November 2019 on the prudential supervision of investment firms and amending Directives 2002/87/EC, 2009/65/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU and 2014/65/EU (link)

National legislation on reporting

  • Act No. 256/2004 Coll., on Capital Market Undertakings, as amended (link)
  • Decree No. 424/2017 Coll., on the reporting duties of some entities operating on the capital market, as amended (link)

Summary information on supervisory reporting is published on the supervisory statistics website (link).

Pursuant to Article 9 of Decree No. 424/2017 Coll., on the reporting duties of some entities operating on the capital market, an entity shall notify the CNB of the contact persons (at least two) for reporting without undue delay by sending the following information to kt.stat@cnb.cz:

  • the first name and surname of the contact persons;
  • the work address, telephone number and e-mail address of the contact persons;
  • The LEI assigned to the investment firm (if the investment firm trades in instruments subject to the reporting obligation in Article 26 of Regulation (EU) No 600/2014 of the European Parliament and of the Council (MiFIR), a LEI code must be assigned to it).

As soon as the CNB receives the information on the contact persons, it will send the investment firm the information it needs to activate the registration, which will give it remote access to the SDAT application. After registration in the SDAT system, an individual reporting obligation will be generated for the entity based on the scope of its licence and planned activities.

The following reporting frameworks in SDAT are relevant to investment firms:

Methodological information for statements in the prudential area is available in Czech and English on the EBA website (link). Methodological information for sending information on transactions is available in Czech and English on the ESMA website (link).

If you have any questions regarding reporting obligations, please contact: