4.V.1.4 Interim conclusion

The introduction of several detailed MiFID I equity (pre-trade) transparency thresholds resulted in a more data-driven transparency regime compared to the ISD. The EU realized that the data-driven approach of MiFID I would require a greater operational quality. NCAs needed to (1) perform equity pre-trade transparency calculations (‘large in scale orders’, ‘liquid market’, and ‘standard market size’) and (2) have data available to perform the calculations and estimates in practice. The MiFID I text covered harmonised provisions on how the calculations and estimates needed to take place. The MiFID I text was mainly the result of CESR providing drafts on calculations/estimates. CESR also provided guidance in the form of an internal guidebook (e.g. how to collect the data, calculation methodologies, and so forth). The EU aim, both apparent in the MiFID I text and CESR guidebook, was to ensure NCAs would perform calculations/estimates in a similar way, as well as being able to perform the calculations/estimates in practice.1 The underlying goal was a common degree of equity pre-trade transparency (similar calculations/estimates across the EU), a related level playing field, and a regime that would work in practice (data collection).