9.II.2.4.1 Goals

The importance of deferral of post-trade data publication as apparent under MiFID I was recognized during the MiFID I-review. ESMA noted there was a justification for delaying publication in order to unwind large positions.1 Similar perspectives were apparent in the MiFIR Proposal of the Commission, as later reviewed by the European Parliament, and Council.2 That being said, there was a concern that under MiFID I the delays were often too long to ensure adequate transparency. CESR/ESMA believed that the overall benefit of improved transparency and reduced information asymmetries across the market outweighed potential costs.3 Accordingly, the lengths of delay became a main element of the MiFID I-review and ultimately the design of the MiFID II equity post-trade transparency regime.