5.VII.4.4 Interim conclusion

The ESMA MiFID II Review reveals how important it is to have a balance between having sufficient and high quality data and simplicity. While the beginning of MiFID II was characterised by an emphasis on the former (sufficient high quality data), ESMA is currently counterbalancing by focusing on simplicity. This is in particular manifests itself in the ESMA proposals on the double volume cap for which ESMA proposes a simpler regime. Another aspect of the data-driven nature of MiFID II is that ESMA has a lot of data available, both reference (FIRDS) and trading data (FITRS). ESMA is looking to improve the trading data (i.e. more data granularity in RM/MTF waivers), whilst certain market participants believe ESMA should do more by building a ‘golden source’ of reference data. ESMA is reluctant to do so, since ESMA is not required to build such a golden source (which could potentially change in the future).