4.II.1.3.1 General

The general MiFID I post-trade transparency obligations were laid down in the MiFID I Directive. The MiFID I Directive required RMs and MTFs to make public ‘at least’: (i) the current bid and offer prices and (ii) the depth of trading interests at those prices (volume) which were ‘advertised through their systems.1 The wording ‘at least’ indicated that the MiFID I pre-trade transparency obligation was minimum harmonised’.2 Member States were permitted to require RMs and MTFs to publish more pre-trade information than obliged under MiFID I. CESR (predecessor of ESMA) in addition clarified that the wording ‘advertised through their systems’ referred to the MiFID I pre-trade information RMs and MTFs at a minimum needed to publish (‘advertise’), not what information actually was published (‘advertised’) through their systems.3