[ESMA 70-872942901-35 MiFIR transparency Q&A, Q&A 6.5]

In case of a corporate action, where a traded ISIN is replaced with a new ISIN, the new ISIN will be treated as a newly admitted to trading or newly traded financial instrument and the ESMA DVC calculations and publication will not take the trading activity of the old ISIN into account.

In addition, while ESMA will publish the percentage of trading in this financial instrument carried out under the reference price waiver and the negotiated transaction waiver from the start of trading, suspensions following the breach of the thresholds set out under Article 5 of MiFIR should only be triggered when at least 12 months of data for the new ISIN is available.

ESMA is however reflecting on ways and means to ensure more continuity in the treatment of financial instruments subject to corporate actions and might decide to revisit this approach in the future.