5.II.1.6.6 Minimum set of equity pre-trade data to publish

MiFID II retains the MiFID I-model in requiring a minimum set of pre-trade data to publish. Reference is made to the initial CESR guidance in drafting MiFID I. Originally, CESR proposed to require all bids, offers and quotes in all different trading models to be made public, that is – the full book. After criticism of respondents to the CESR consultation, CESR revised its advice to require ‘a minimum level of pre-trade information’. A similar perspective is apparent under MiFID II, that is – a minimum set of equity pre-trade data needs to be published (top-down). RMs and MTFs can exceed the MiFID II equity pre-trade transparency standards by voluntarily publishing more and/or faster equity pre-trade data.1