How should the “Instrument identification code” fields (Table 2, Field 41 of RTS 22 and Table 3, Field 1 of RTS 23) be populated for DLT financial instruments that are the digital representation of a previously issued financial instrument?

According to Article 26(5) of MiFIR, TVs shall report on behalf of firms that are not subject to the transaction reporting regime. In a DLT MTF or TSS operating under the DLT Pilot regime, the DLT MTF or DLT TSS may admit natural persons as members executing transactions. How should DLT MTFs or DLT TSS report on behalf of natural persons that are not subject to Article 26 of MiFIR?

How should Field 3 “Trading venue transaction identification code” (TVTIC) of RTS 22 be populated in case the entity executing the transaction is a natural person and not an investment firm?

Should DLT MTFs/TSS populate Field 40 – Complex trade ID of RTS 22?

How should a DLT transaction fee be considered in the context of populating Field 33 “Price” of RTS 22? Should DLT transaction fees be included in the price related fields?