ICMA responds to ESMA's MiFIR review report on the obligations to report transactions and reference data


20 November 2020 On 24 September, the European Securities and Markets Authority (ESMA) published a consultation paper examining transaction reporting and reference data obligations under the Market in Financial Instruments Regulation (MiFIR) (the Consultation Paper). ICMA's response is now available.

ICMA believes that ESMA is trying to reduce overlap between MAR and MiFIR regulations, as well as making better cross-over use of the technology between the market abuse and MiFIR transparency teams. However, ICMA members question whether the benefit of an expanded scope (potentially creating excess unusable data [see paragraph 43 of the consultation paper]) will bring the claimed aims of market resilience, liquidity and efficiency to the financial industry participants. This consultation paper is particularly complex requiring detailed answers. ICMA members focused on questions concerning transparency, market structure impacts, scope of instruments (TOTV) and reference data.
ICMA Zurich

T: +41 44 363 4222
Dreikönigstrasse 8
8002 Zurich
ICMA London

T: +44 20 7213 0310
110 Cannon Street
London EC4N 6EU
ICMA Paris

T: +33 1 70 17 64 72
62 rue la Boétie
75008 Paris
ICMA Brussels

T: +32 2 801 13 88
Avenue des Arts 56
1000 Brussels
ICMA Hong Kong

T: +852 2531 6592
Unit 3603, Tower 2
Lippo Centre
89 Queensway, Admiralty
Hong Kong
Copyright © 2022 International Capital Market Association.