18 January 2019
National Identifier (NID)
Identifiers to be provided under MiFID II
To comply with the Markets in Financial Instruments Directive (MiFID II), from 3 January 2018 clients are required to state their date of birth, nationality and national identifier when buying or selling financial instruments. This document contains the necessary information on the type of national ID you must provide as a client and what you need to do if you hold multiple nationalities.
How are individuals identified under MiFID II?
Within the framework of MiFID II the ESMA (European Securities and Markets Authority) uses a suite of identifiers, based on the individual’s nationality.
You will find these details in Regulatory Technical Standard (RTS) 22 and in the table below, which shows the required identifiers for each nationality and the identification codes to be used.
CONCAT as an identification code
CONCAT is a method of generating an identification code (ID) for individuals by means of the compression or concatenation of four data elements in the following order:
1. Country code (2 characters: ISO 3166-1)
2. First name (the first 5 characters padded with # where required)
3. Surname (the first 5 characters padded with # where required)
4. Date of birth (YYYY-MM-DD)
Unfortunately, the CONCAT code is not unique and in some cases several people may be identified by the same CONCAT.
- 6 countries (Austria (AT), Germany (DE), France (FR), Hungary (HU), Ireland (IR) and Luxembourg (LU)) use the CONCAT approach as the sole identification code.
Other identification methods
- Other countries – such as Belgium – use national identifiers, passport numbers or tax numbers. ING normally has access to this data. If it does not, ING can generate a CONCAT ID or request the national identification code.
- 6 countries (Estonia (EE), Spain (ES), Iceland (IS), Italy (IT), Malta (MT) and Poland (PL)) do not use CONCAT as an identification code. This means that ING must request the national identification code from its clients.
Country of origin
The country of origin is used to determine which national proof of identity you have to provide as a client. This is the country or countries of which you are a national, by birth or naturalisation, and may not correspond to the country in which you live or work.
The tables on the following pages show which information has priority. If you are a Belgian national, you need to provide your National Registration Number. If you do not have this, ING will generate an ID code using a combination of your nationality, country code, first name, surname and date of birth (CONCAT). There is no third option for Belgians.
What if you hold multiple nationalities?
Follow the rules below to determine which nationality you should choose:
If you hold multiple nationalities, select the European country from the ‘European countries’ table.
If you hold multiple European nationalities, use the nationality of the country that comes first in the ‘European countries’ table in this document.
If you hold multiple non-European nationalities, use the nationality of the country that comes first in the ‘non-European countries’ table in this document.