5.VI.3.6 Background

MiFID I – CESR and ESMA in particular – already introduced a data infrastructure for the purposes of EU equity pre-trade (and post-trade) transparency provisions (i.e. the MiFID I Database). When it became apparent that MiFID II would expand (1) the scope in terms of financial instruments and (2) transparency thresholds compared to MiFID I, the EU recognized that MiFID II would require a new data infrastructure. FIRDS, FITRS, and the DVC Database were designed for these purposes (the SI calculation database is a temporary solution created by ESMA on a voluntary basis).1 Combined with delegations from NCAs to ESMA, the idea was to set up an EU database in a ‘one-stop shop’.2

The implementation of the three databases (FIRDS, FITRS, and DVC Database) proved to be challenging. The technical infrastructure that needed to be set up would require ESMA to collect data from about 100 trading venues (and another 200 through NCAs) on about 15 million financial instruments (compared to only RMs and with just one tenth of the number of financial instruments in the MiFID I data system).3 ESMA informed the Commission that neither the NCAs nor the industry would have the necessary systems ready by 3 January 2017, being the initial starting date of the MiFID II regime. Considering this exceptional situation and in order to avoid any legal uncertainty and potential market disruption, a one-year delay of MiFID II was deemed necessary (i.e. until 3 January 2018).4