Quick Find:
MiFID II/R implementation in secondary markets
The objectives of MiFID II/R are to increase market transparency, efficiency and safety by bringing the majority of non-equity products into a robust regulatory regime and moving a significant part of OTC trading onto regulated platforms.

MiFID II/R Level 2

MiFID II/R brings much of the transparency traditional in equity markets to bond trading. Europe will go further with bond transparency rules than just about anywhere in the world, including the US. MiFID II/R’s regulatory regime brings into effect pre-trade transparency for bonds as well as post-trade. This will result in a significant impact on the market structure of bond markets. Bond pre-and post-trade transparency requirements will be calibrated for different types of bond market trading structures such as order-book, quote-driven, hybrid and periodic auction trading systems. In order to calibrate bonds correctly for MiFID II/R transparency obligations, IT systems have had to be enhanced, developed or built from scratch - a major undertaking for the industry. Banks, regulators and investors are dependent on data collected to meet MiFID II/R’s commitments.

Owing to the need for an IT build both by National Competent Authorities and by the industry, MiFID II/R has been delayed by one year and has taken effect on 3 January 2018. 

MiFID II/R timeline:

MiFID II/R and MiFIR entered into force on 3 January 2018, following a 12-month delay agreed by legislators in June 2016 from the original date of 3 January 2017. 

ESMA is expected to publish further Q&As to assist market participants in understanding the Level 2 text.

MiFID II/R and Fixed Income: an overview
Includes MiFID II’s pre- and post-trade transparency requirements (including SI Regime), new market structure, best execution reporting obligations, and new research dynamics.

See also: MiFID II/R implementation (covering primary markets, secondary markets, repo markets and asset management).


February 2018
ICMA Briefing note - ESMA Q&A update on transparency and market structure topics (7 February 2018)
ICMA Notes - Early Days MiFID II meeting - 1 February 2018

January 2018
A briefing note on ESMA liquidity assessments of individual bonds for MiFID II/R implementation
ESMA guidance on the implementation of MiFID II/R
MiFID II/R implementation workshops: key takeaways

December 2017
ESMA statement on LEI implementation under MiFID II
Overview of MiFID II deferral regimes in EU Member States
Liquidity assessments of individual bonds for trade reporting

November 2017

FAQs on MiFID II/R and SFTs (updated November 2017)
A briefing note on ESMA Q&A updates on MiFID II / MiFIR transparency topics (15 November 2017)
A briefing note on ESMA Q&A updates on MiFID II / MiFIR investor protection and intermediaries (10 November 2017) and ESMA Q&A updates on MiFIR data reporting (14 November 2017)
October 2017
MiFID II/R implementation: ESMA guidance
MiFID II/R implementation: road tests and safety nets
A briefing note on ESMA Q&A updates on MiFID II/MiFIR transparency and investor protection

September 2017
MiFID II/R FAQs on extra-territoriality

August 2017
Request for clarification from ESMA on hedging and new issues (packages)

July 2017
Practical challenges of implementing MiFID II/R in secondary markets
MiFID II/R implementation in secondary markets
A briefing note on ESMA Q&A updates on market structure, data reporting (7 July) and best execution (10 July) under MiFID II / MiFIR
A briefing note on ESMA interim transparency calculations for non-equity instruments (excluding bonds) under MiFID II
Summary note of the ICMA MiFID II/R Implementation Workshop, London, 4 July 2017
Presentation on Transparency, Best Execution & Emerging Market Structure Trends, Ben Pott, 4 July 2017

June 2017
A briefing note on MiFID II/R costs and charges for fixed income market-makers (bonds and repo)
A briefing note on ESMA Q&A updates on MiFID II/R transparency topics and the ESMA Opinion on 3rd country trading venues
A briefing note on the ESMA Opinion on the concept of “Traded on a trading venue” (TOTV) under MiFID II and MiFIR

May 2017
MiFID II/R Post-trade transparency: trade reporting deferral regimes. An ICMA Position Paper

April 2017
A briefing note on ESMA Q&A on MiFID II/R investor protection (research)
A briefing note on ESMA Q&A on MiFID II/R transparency topics (post-trade reporting obligation)
A briefing note on ECMI-CEPS roundtable on MiFID II/R transparency for non-equity markets
A briefing note on ESMA Q&A on MiFID II/R Organised Trading Facilities (OTF) and Systematic Internalisers (SI)
ICMA MiFID II/R Systematic Internaliser Workshops: summary report
MiFID II/R implementation: the Systematic Internaliser regime
A briefing note on ESMA Q&A on MiFID II/R Best Execution

March 2017
A briefing note on ESMA’s final report on draft RTS for package orders

February 2017
Discussion paper on MiFID II/R Best Execution and Securities Financing Transactions
ERCC letter to the European Commission regarding the applicability of MiFID II/R best execution to SFTs

December 2016
ESMA Consultation Paper on Consolidated Tape – ICMA Submission

November 2016
ICMA ‘FAQ’ on systematic internalisers for bond markets
A briefing note on systematic internalisers for bond markets

October 2016
SFT Reporting Requirements

September 2016
MiFID II/R Fixed Income Best Execution Requirements RTS 27 & 28

April 2016
MiFID II/R Transparency and Best Execution presentation (Q2 2016)

March 2016
ICMA response to FCA CP: Markets in Financial Instruments Directive II Implementation – Consultation Paper I Q6, 8, 12 and 13
MiFID II/MiFIR – Transparency & Best Execution requirements in respect of bonds - presentation Q1 2016

15 June 2015
JAC response to ESMA Consultation Paper - Draft guidelines on complex debt instruments and structured deposits (item 40 on the ICMA retail structured products webpage)

2 March 2015
ICMA responded to an ESMA Consultation Paper on MiFID II/MiFIR


Level 1:
Markets in Financial Instruments (MiFID II) - Directive 2014/65/EU
Markets in Financial Instruments (MiFIR) - Regulation (EU) No 600/2014

Level 2:
Overview and state of play of RTS and ITS relating to MiFID/MiFIR
ESMA – Policy activities related to MiFID (II) and MiFIR  

RTS 2: Transparency requirements for trading venues and investment firms in respect of bonds, structured finance products, emission allowances and derivatives
Annex to RTS 2

RTS 27: Best Execution – Reporting criteria
Annex to RTS 27

RTS 28: Best Execution – Quality of execution
Annex to RTS 28

Level 3:

MiFID (II) - Investor Protection:

Q&A on MiFID (II) and Investor Protection

MiFID (II) MiFIR and Secondary Markets:

Q&A on MiFID II and MiFIR transparency topics

Q&A on MiFIR data reporting

Q&A on MiFID II and MiFIR market structures topics

MiFID II Transitional Transparency Calculation

FAQs on MiFID II - Interim Transparency Calculations

Notes & Briefings:

ESMA Briefing on the Legal Entity Identifier (LEI) – 9 October 2017 (ESMA70-145-238)
ESMA Briefing - MiFID II technical data reporting requirements - 16 January 2017 (ESMA00-6-265)

ESMA Note on MIFID/MIFIR implementation: Delays in the go-live date of certain MIFID provisions - 17 November 2015 (ESMA/2015/1514)

Resources related to transparency calculations and liquidity assessments of bonds:
ESMA Transparency Calculations
ESMA List of bonds deemed liquid or illiquid [for other asset classes, ESMA only includes the instruments that are liquid – for bonds illiquid instruments are also listed]
ESMA LIS and SSTI thresholds for bonds
ESMA List of credit derivatives deemed liquid
ESMA List of interest rate derivatives deemed liquid
ESMA FAQ document related to MiFID II Transitional Transparency Calculations
ESMA Financial Instruments Transparency System (FITRS)

See also:


Liz Callaghan
Director, Market Practice and Regulatory Policy; Secretary to the ICMA Secondary Market Practices Committee
Direct line: +44 20 7213 0313

Andy Hill
Senior Director, Market Practice and Regulatory Policy; secretary to the ICMA Secondary Market Practices Committee.
Direct line: +44 20 7213 0335

Gabriel Callsen
Associate, Market Practice and Regulatory Policy

Direct line: +44 20 7213 0334