17.III.4.2.4 Charge at the level of disaggregated pre- and post-trade data

As noted, MiFID II requires RMs and MTFs to charge the data on a reasonable commercial basis at the level of disaggregated data. This requirement can be seen as the starting point to apply the reasonable commercial basis-standard, that is – at the minimum level that MiFID II expects data to be separated. The MiFID II aim of disaggregating pre- and post-trade data, being lower data costs, would be reduced where the prices of the disaggregated data would be raised on an individual level. ESMA acknowledged this during the MiFID II drafting process. ESMA proposed that the principle of a reasonable commercial basis needed to apply at the disaggregated level of the separate data products.1 This perspective is also evident in the final MiFID II-text.