13.III.1.1 General

As noted above, an APA or ‘Approved Publication Arrangement’ refers to a person authorized under MiFID II to provide the service of publishing post-trade reports on behalf of investment firms.1MiFID II obliges investment firms trading outside an RM or MTF to make MiFID II equity post-trade data public through an APA.2MiFID II provides rules for APAs to support the establishment of a consolidated tape for equity post-trade data.

To date, MiFID II has not materialised a consolidated tape. No CTP has been authorized under MiFID II and data quality issues have been observed with APA publication. ESMA and the Commission are reviewing the current MiFID II framework to see what changes have to be made, including with respect to APAs. The text below examines the current MiFID II text for APAs. The MiFID II Review of ESMA and the Commission can be found in section V below.