13.IV.3.3 Technical accessibility

MiFID II requires SIs to make their quotes ‘easily accessible’.1 Where an SI uses proprietary arrangements, the requirement of ‘easily accessible’ is almost the same as for quote publication through RMs, MTFs, and/or APAs. Similar requirements are that the publication through proprietary arrangements needs to be: (1) machine-readable2 and (2) findable for market participants (i.e. a SI needs to specify where the SI publishes the quotes).3 The difference is that an additional requirement applies where an SI publishes the quotes only through proprietary arrangements (i.e. the quotes are not also published through RMs, MTFs, or APAs). In this situation, the SI needs to make the quotes, in addition to machine-readable, also available in a human-readable format.4 Quotes are considered to be published in a human-readable format where: (a) the content of the quote is in a format which can be understood by the average reader; and (b) the quote is published on the SI’s website and the website’s homepage contains clear instructions for accessing the quote.5 The aim of the human readable-requirement is to make the quotes available to average investors that only visit the SI’s proprietary arrangements.