13.IV.6.1 Industry-led consolidation services

Where MiFID II provides equity post-trade transparency provisions on Consolidated Tape Providers (CTPs), no equivalent regime is provided with respect to equity pre-trade transparency. MiFID II permits CTPs to provide additional services in the area of pre-trade information, including the collection and consolidation of equity pre-trade information.1 As the wording ‘permits’ and ‘additional’ already suggest, the consolidation of equity pre-trade data is not the core task of CTPs. The main rationale of MiFID II in introducing CTPs is to collect and consolidate post-trade data (not: pre-trade data).2MiFID II does not provide a framework where competing so-called ‘Consolidated Quote Providers’ (CQPs) need to collect and provide equity pre-trade data in a consolidated manner (although in theory CTPs are permitted to do so). MiFID II instead relies mainly on market forces to provide a stream of consolidated equity pre-trade data.3 Except for additional pre-trade services of CTPs, MiFID II changes little to the previous regime (MiFID I) when it comes to providers of consolidation services.