17.II.1 General

MiFID II requires RMs and MTFs to make pre- and post-trade trade available in a separate way, that is – not as one product. The separation of pre- and post-trade data is also referred to as ‘unbundled’ or ‘disaggregated’ pre- and post-trade data. The MiFID II rules serve two closely related goals. First, the unbundling of pre- and post-trade data is considered as a precondition to support consolidated data under MiFID II, especially in the area of post-trade transparency. The unbundling of pre- and post-trade data means that in theory the consolidation of pre- and post-trade data should be more easy to achieve.1 Second, and closely related to the first goal, the MiFID II data separation-rules have the aim to reduce costs for market participants when purchasing market data.2 The aim here is to ensure that to the extent possible, each customer for data only pays for the data it wants, rather than being forced to pay for extra data in which it has no interest.3 This should also reduce the price of consolidated data in Europe, for which MiFID II emphasizes the price of consolidated post-trade data.4