The EACB welcomes the opportunity to participate in ESMA’s consultation on three mandates for the European Commission to review the MiFID II/MiFIR rules, with respect to Article 52(7) of MiFIR, Article 90(1)(g) of MiFID II and Article 90(2) of MiFID II. We note that these mandatescover the development in prices for pre- and post-trade transparency data from regulated markets, as well as, the functioning of the consolidated tape (CT) for equity instruments.
The relevant topics of market data and consolidated tape were one of the main objectives of MiFID II in increasing market transparency. However, the EACB notes that due to the complexity of the regulation, issues of data availability, poor data quality, and the increases in the costs of market data, this objective has not been achieved.
Therefore, our members strongly support the need for a CT and a comprehensive analysis of the transparency rules with respect to market data.