13.IV.2.2 Details: content and formats

MiFID II requires RMs, MTFs, and APAs to publish SI quotes by using the standards and specifications required for certain (not: all) MiFID II equity post-trade data reports.1 Accordingly, RMs, MTFs, and APAs need to publish SI quotes including the currency, date and time, ISIN (instrument security identification number) and MIC (market identifier code). The MiFID II requirements for the equity pre-trade reports of SI quotes are in effect overall less strict compared to the MiFID II standards for publishing equity post-trade reports (i.e. less prescribed standards).2

Although less strict in terms of less prescribed standards, in contrast to the MiFID II equity post-trade reports, MiFID II does require SIs to disclose their identity in the quote in case the SI quotes (pre-trade data) are made public through the arrangements of an RM, MTF or an APA.3 ESMA clarified this in a Q&A.4 The rationale for publishing the SI identity in pre-trade reports of RMs, MTFs, and APAs seems to be a practical one, namely to enable investors to find the SI that publishes the quote, regardless of the publication arrangement used (RM, MTF or APA). The lack of SI identity in MiFID II post-trade reports is to protect the SI against position risks following a trade.5MiFID II intends to protect SIs against position risks prior to a trade (pre-trade) through different means, namely the specific MiFID II SI pre-trade transparency requirements (rather than through removal of SI identity in the pre-trade reports).6

Last, but not least, where an SI uses an RM, MTF, or APA to publish the SI quotes, MiFID II requires the RM, MTF, or APA to publish the information (content, such as the currency) in accordance with a certain ISO-format (International Organization for Standardization).7 The MiFID II requirements are stricter compared to MiFID I. Under MiFID I CESR only ‘encouraged to consider ISO formats’ (and content where relevant) when the publication arrangement was ‘making system changes’.8MiFID II is in effect more top-down by requiring publication of the SI quote information in the ISO-format. The aim here is to improve the comparability of the SI quotes across the European market.