28 March marked the entry into force of the changes to the Markets in Financial Instruments Regulation (MiFIR), as introduced by the latest MiFIR review. In a statement released before the transition to the new rules, the European Securities and Markets Authority (ESMA) acknowledges that “public guidance is necessary”. Changes that might be noteworthy for the post-trade sector include the ones concerning consolidated tape providers (CTP), and post-trade transparency for bonds and non-equity instruments.

The consolidated tape

Trading venues and APAs, the organisations named for approved publication arrangements (APA), the type of data they provide, are required to send regulatory and core market data to CTPs in “as close to real time as technically possible”, and via a “high quality transmission protocol”. ESMA’s next step would be to define the required quality of transmission protocol and the duration that qualifies as “real time”.

CTPs for shares and ETFs should display the best bid and offer spread of each trading venue at the time of the executed trade, as well as the European best bid and offer based on the data. Core market and regulatory data have to be disseminated “as a continuous electronic data stream on non-discriminatory terms as close to real time as technically possible”.


In lieu of private actors expressing interest to act as CTPs, the updated MiFIR empowers ESMA to select a CTP for each asset class, beginning with bonds, followed by shares, and finally, derivatives.

Post-trade transparency for bonds

The new rules aim to harmonise the deferral of fixed income post trade report publication. To this end, trading venues are now required to disclose to market participants and the public any such deferrals. The revision proposes five categories for maximum deferral periods, each applying to a different size tier of transactions.  

Post-trade transparency for non-equity instruments

The deferral regime for exchange-traded derivatives and OTC derivatives in the revised MiFIR is separate from that of other non-equity instruments. Like with the bonds, it is divided into five categories, but here, each applies to a different size and liquidity tier of transactions. ESMA has yet to define the transaction size, and the price and volume deferrals applicable for each category.