13.III.4.1.1 Lack of high quality and consolidated equity post-trade data

The MiFID II Level 1 framework is a response to MiFID I. MiFID I increased both competition in terms of trading platforms, as well as in data services. Although MiFID I brought substantial benefits to investors, such as reduced transaction costs and choice, market data fragmented across different venues and could be made available through a number of different sources.1 During the MiFID I-review, CESR believed that although many data vendors provided consolidated data, these services were not of a standard that fully satisfied market participants.2 Concerns were especially acute in the area of equity post-trade publication, where MiFID I broadened the post-trade transparency requirements to all investment firms (under the ISD equity post-trade data was mainly published by RMs).3 Concerns were expressed over the quality of equity post-trade data, including errors, timing of publication, and various barriers to consolidation of equity post-trade data.4 The main concerns were expressed about (equity) post-trade data from trades taking place outside RMs and MTFs. RM and MTF data was generally considered to be of high quality.5 Below, the focus is therefore on the framework for APAs (not: RMs and MTFs). The APA framework which will be followed by a discussion of the MiFID II CTP regime.