13.III.3.3 Details: content, flags, and formats

MiFID II requires CTPs to publish the same details as RMs, MTFs, and APAs.1 Hence, CTPs are also required to publish the same (1) content, (2) flags, and (3) format as prescribed by MiFID II for RMs, MTFs, and APAs.2 The rationale of the same publication standards is to enable CTPs to easily collect the published equity post-trade data from RMs, MTFs, and APAs, that is - CTPs do not have to ‘map’ different datasets.3 In effect, MiFID II requires CTPs to publish the following equity post-trade data: (a) the identifier of the financial instrument; (b) the price at which the transaction was concluded; (c) the volume of the transaction; (d) the time of the transaction; (e) the time the transaction was reported; (f) the price notation of the transaction; (g) the code for the trading venue the transaction was executed on, or where the transaction was executed via a SI the code ‘SI’ or otherwise the code ‘OTC’; (h) where applicable, the fact that a computer algorithm within the investment firm was responsible for the investment decision and the execution of the transaction; (i) if applicable, an indicator that the transaction was subject to specific conditions; and (j) where applicable, a flag to indicate that the reference price or negotiated trade waiver for liquid instruments was used to waive the MiFID II pre-trade transparency obligations.4 The requirement is minimum harmonized (‘at least’). This means that Member States are allowed to require CTPs to publish more details than MiFID II prescribes.5 For an examination of the CTP flags and formats, reference is made to the examination of the flags and formats for RMs, MTFs, and APAs (being the same as for CTPs) (see paragraph 1.2 above).6