4.V.2.5 Interim conclusion

The next step of making calculations and estimates for the MiFID I equity pre-trade transparency regime was to publish the results. For this reason, MiFID I introduced top-down elements in the area of result publication. In contrast to the ISD, where equity (pre-trade) transparency calculations and estimates were a national matter, MiFID I introduced harmonised publication requirements for NCAs and CESR. NCAs were required to publish the calculations and estimates, unless CESR already published the results on behalf of the NCA. Additionally, CESR needed to publish the individual NCA results in a consolidated manner. CESR operated two databases (MiFID I Database for Shares Admitted to Trading on an RM and the MiFID I Database for SIs) to ensure the consolidated view. The MiFID I aim of the top-down approach was to ensure all market participants across the EU would have access to data relevant for the equity pre-trade transparency regime, namely to observe (1) ‘large in scale orders’, ‘liquid shares’ and the related ‘standard market size’, as well as (2) the degree of SI activity. The common publication standards of MiFID I were in place to ensure a similar approach across the NCAs, including a consolidating role for CESR, in publishing the results at the EU level.