13.III.3.1 Scope of the CTP framework

As noted in paragraph 2 above, MiFID II introduces the concept of CTPs. A CTP is a person authorised to provide the service of collecting equity post-trade information from RMs, MTFs, and APAs, and consolidating the information into a continuous electronic live data stream providing price and volume data per equity instrument.1 Hence, a CTP performs two core tasks, namely: (1) the consolidation and (2) publication of MiFID II post-trade data. To qualify as a CTP, the person consolidating and publishing the post-trade data needs to satisfy MiFID II requirements for CTPs.2 The MiFID II Directive requires CTPs to have adequate policies and arrangements in place to collect the MiFID II equity post-trade data as published by (a) RMs and MTFs; and (b) APAs. After the collection, the CTP needs to consolidate the equity post-trade data into a continuous electronic data stream.3 A directly applicable MiFIR Delegated Regulation provides the financial instruments data that needs to be provided in the data stream. The MiFIR Delegated Regulation requires a CTP to include in its electronic data stream all MiFID II equity post-trade data that RMs, MTFs, and APAs need to publish under MiFID II.4 When a new RM, MTF or APA starts operating, a CTP needs to include the data made public by the new entity as soon as possible, and in any case six months after the start of the RM’s, MTF’s or APA’s operations.5 The rationale here is to ensure the comprehensiveness of a CTP. The aim is to ensure that a CTP consolidates and publishes 100% of equity post-trade data, whether the equity instrument is traded on or outside an RM or MTF.6