This educational document provides our members with a structured approach to understanding the post-trade transparency (PTT) obligations defined under Article 6, 10, 20, and 21 of MiFIR. This document also highlights the key challenges and practical implementation options for the impacted qualifying investment firms to consider as they progress with plans to be MiFID II compliant.

This document will cover

• Firms impacted by MIFID II / MiFIR’s post-trade transparency requirements
• The data required to be reported
• When and where the data is to be reported
• Reporting scenarios
• Challenges that market participants will need to consider in order to implement the necessary reporting solutions
• Explanation of the relevant terms such as Approved Publication Arrangements (APAs), Systematic Internaliser (SI) and post-trade transparency deferrals

This document will not cover

• Transaction or position limit reporting
• Inducements or any contractual arrangements between counterparties
   

This document is a collective effort by a number of subject matter experts (SMEs) from across the industry on the AFME PTT Working Group. This document incorporates feedback from SMEs with industry and regulatory experience and after a series of consultation discussions.