9.IV.3.1 General

MiFID II covers a framework to ensure the reference data and results of the calculations/estimations are publicly available. Similar to MiFID I, MiFID II has databases in place to publish the data. New under MiFID II is the scale of the operations. The extension of the MiFID II scope required a brand new system, among other things, for the purposes of the MiFID II equity post-trade transparency provisions.1 The scale of operations was so great that it resulted in a delay of MiFID II for a year (3 January 2018 instead of 3 January 2017).2 Two databases are of particular relevance for the MiFID II equity post-trade transparency regime, namely: (1) FIRDS (reference data) and (2) FITRS (data for the main post-trade transparency calculations). In contrast to the MiFID II equity pre-trade transparency regime, the two databases for (a) the double volume cap and (b) data for SI calculations, are not relevant for the MiFID II equity post-trade transparency regime. Besides the FIRDS and FITRS (and databases for the double volume cap/SI calculation data), MiFID II covers registers for (i) investment firms and (ii) RMs, MTFs (and OTFs), SIs, and data reporting service providers (including APAs and, where authorised, CTPs).3 The focus of this paragraph is on FIRDS and FITRS. The reason to focus on FIRDS/FITRS is the particular implementation challenges involved with these two databases as relevant for the MiFID II equity post-trade transparency regime.