9.IV.2.2.3 Frequency of data requests and response times

Related to the content provisions are the MiFID II requirements that specify the frequency of data requests and the response time for the submitting parties. A MiFIR Delegated Regulation notes that periodic data (see paragraph above) needs to be submitted by RMs, MTFs, APAs, and CTPs on a daily basis.1 The rationale of the daily submission requirement is best understood against the broad range of financial instruments covered and the large amount of data that NCAs (or ESMA in case of delegation) need(s) to process. In light of this great amount of data, the MiFID II daily submission requirement are in place to ensure more accurate file processing, as well as an efficient and timely management of data submission, data quality checks and data processing.2 The daily submission requirement is also in place to simplify the submission requirements for RMs, MTFs, APAs, and CTPs (i.e. submission is required once a day, instead of using different timeframes).3

MiFID II covers a longer response time for ad hoc data. RMs, MTFs, APAs, and CTPs need to submit ad hoc data to the NCA (or ESMA in case of delegation) within four weeks after the request.4 The longer submission date compared to the daily submission requirement is to give extra time to RMs, MTFs, APAs, and CTPs, given the less automated and standardised nature of ad hoc data compared to periodic data.5