Article 16 - Record-keeping and order handling - Aqta verifier

Article 16(6) requires an investment firm to arrange for records to be kept of all services, activities and transactions it undertakes, sufficient to enable the competent authority to fulfil its supervisory tasks and to perform enforcement actions. The clause is about supervisory reconstructability: a firm must be able to show, after the fact, what it did and in what order.

What Article 16(6) and 16(7) ask for

Records sufficient to enable the competent authority to ascertain that the firm has complied with all obligations, including those with respect to clients and to the integrity of the market. Under Article 16(7), records include the recording of telephone conversations or electronic communications relating to, at least, transactions concluded when dealing on own account and the provision of client order services that relate to the reception, transmission and execution of client orders.

Receipt-field mapping

request_hashReconstructable record of the instruction or input (SHA-256 over canonical request bytes)

model + outcomeWhat the firm’s system did and which model produced it

policy_appliedWhich order-handling policy was in force at the time of the activity

timestampWhen the activity occurred, so a sequence of order handling can be reconstructed

signature + public_keyNon-repudiable evidence the firm emitted the record

attestation_id + prev_attestation_idHash chain that shows the sequence has not been altered after the fact

A receipt gives the record-keeping obligation a per-activity artefact a competent authority can verify against the published key, without access to the firm’s systems. Designed for the reconstructability Article 16 asks for. Aqta issues signed evidence, not a certification of MiFID II compliance.

Read Article 16 on EUR-Lex or read the full open spec at github.com/Aqta-ai/attestation-spec.

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