8.III.1.3.1 General

The general post-trade transparency obligations were laid down in the MiFID I Directive. The MiFID I Directive required investment firms to make public ‘at least’ (1) the price; (2) the volume; and (3) the time of the transactions executed in shares admitted to trading on an RM.1 The term ‘at least’ indicated that the obligation was minimum harmonised. Member States were permitted to lay down stricter post-trade transparency obligations than set out under MiFID I.2 MiFID I did not require investment firms to make public their identity when transacting outside an RM or MTF. MiFID I ‘only’ required the investment firm to publish the general code ‘OTC’, unless the investment firm was an SI.3 An exception to the foregoing was in place for SIs in case the SI published aggregated quarterly data as to the transactions executed in the SI capacity. In this situation, the SI could publish a general ‘SI’ code.4 The rationale of the exception was to protect the SI against position risks due to identity exposure.5