Two decades after MiFID I set out to introduce competition into European equity markets, the regulatory project has reshaped market structure without finishing the job it was meant to do. That, at least, was the thesis put to the opening panel at A-Team Group’s inaugural ExchangeTech Summit London earlier this month, entitled “Navigating the European markets landscape: Competitiveness, strategy and the Exchange’s role in liquidity.”
The hour that followed offered a working map of where the unfinished business now sits. Successive waves of European market structure reform have introduced choice at the execution layer but failed to dismantle the structural advantages of the incumbents. The cost of market data, asymmetries between venues, the absence of mandated data standards, monopolies in closing auctions and index data, the lack of full interoperability in clearing – none of these, on this reading, has been resolved. The level playing field that pro-competition policy was supposed to deliver still does not exist.Setting out the discussion were Simon Dove, Managing Director and Head of Liquidity EMEA at Instinet; Adam Matuszewski, Head Cash Market Products and Managing Director at SIX Swiss Exchange; Jon Relleen, Director of Infrastructure & Exchanges, Supervision, Policy & Competition – Markets at the Financial Conduct Authority; and Michael Stanley, Execution Services – Sales & Product Development at Virtu Financial, with Niki Beattie, Strategist and Financial Market Structure Expert, in the chair. What followed was less a debate about whether the competitive promise had been kept than a stocktake of which layers of the value chain have been reshaped, which have been bypassed, and where the next phase of policy will need to land.
Trading: more competition than the headline suggests
The opening pushback came on whether the trading layer is in fact where the competition problem lives. One panellist argued that European equity trading is not short of competition but short of innovation. Closing auctions were offered as a case in point: primary venues hold approximately 50% of closing auction volumes, with the rest fragmented across systematic internalisers trading at the close, internalised flow, and MTF alternatives, including one challenger venue expanding its market-at-close functionality with additional order types this year. The argument was not that primary venues face no advantage – it was that calling the position a monopoly overstates the case.
Another panellist challenged the broader characterisation of trade execution as uncompetitive. The execution landscape is fragmented; the share of volume on central limit order books is, if anything, a more pressing concern than the lack of choice between venues. The FCA’s consultation paper CP25/20, published in July 2025, set out exactly this concern – noting a marked shift away from central limit order book trading towards bilateral execution mechanisms, and raising questions about the continued effectiveness of the current transparency framework. Feedback is now informing a further consultation on UK equity market structure, expected in the first half of 2026.A related question surfaced beneath the disagreement: whether venues competing for execution share are doing so by genuinely growing the available liquidity or by recycling what already exists. When venues offer materially similar products, the proliferation of choice imposes costs without delivering corresponding liquidity gains.
The internalisation question
The most pointed challenge to the framing of competition as a contest between visible execution venues came from a different direction. Internalised swap-versus-swap trading in European equities now averages more than €10 billion in daily notional, according to one panellist – activity that does not print to the market and is therefore invisible from a liquidity-formation standpoint. Where a tier-one broker is given 100 closing orders to work, 60 to 70% will be internalised, with two-thirds of that internalised volume going unprinted.
If a material share of European equity volume is being matched bilaterally without contributing to public price formation, the framing of competition as a venue-level question misses where the real distortion lies. Other panellists acknowledged that the drivers of internalisation – cost pressure, the economics of running an SI, the revenue internalisation generates inside broker businesses – are now part of the structural picture in a way they were not a decade ago.
Market data: the new battleground
Market data drew the most concrete disagreement of the session. One panellist cited a 600% increase in the market data cost paid by their MTF following a pricing change by a major continental exchange group earlier this year. The figure was offered without independent corroboration, but the structural mechanics are not in dispute. European exchanges’ fee schedules differentiate sharply between display data, used by physical users at terminals, and non-display data, used by trading systems – with non-display fees tiered further by use case, and MTFs sitting in a higher tier than brokers. Multiple European venues have revised their fee schedules repeatedly across the past two years. Across the major venues, market data revenues have risen significantly as a share of equity market revenue – Deutsche Börse from around 21% to 31%, Euronext from around 11% to 19%, Nasdaq Nordics from 19% to 23%, according to one industry study published earlier this year.
The exchange-side defence of these economics is that exchanges are not simply matching engines. They are price-discovery utilities operating under legal obligations to enforce listing rules, police market abuse, invest in deterministic execution infrastructure, and run surveillance. Memory and low-latency hardware costs have themselves risen by around 20% in the past year. That defence does not, however, address whether market data revenues are now subsidising trading economics, replacing them, or operating as a parallel profit centre. The chair’s intervention was sharp: a market data business framed independently of the trading activity that produces the data is a phantom business.
The consolidated tape, finally moving
The clearest piece of forward-looking policy news came on the consolidated tape, and on both sides of the Channel. The EU equities and ETFs tape, to be operated by EuroCTP – a joint venture established by Europe’s leading exchange operators, including Euronext, Nasdaq, SIX and others – is targeting a July 2026 launch under ESMA supervision, with technology partner Exegy already onboarding contributing venues into a test environment ahead of go-live. The UK bond consolidated tape, awarded to London-based market data and regtech firm Etrading Software, is targeting a 22 June 2026 launch, with the FCA having signed the provider contract in January 2026 following resolution of a legal challenge. The UK equities consolidated tape sits on a separate, slower timetable: the FCA published its consultation paper (CP25/31) in November 2025 and is targeting a policy statement in the first half of 2026, with procurement to follow and a service in operation during 2027.
The tapes are framed as a step towards greater transparency rather than as a corrective to data costs at the venue level. For the venues, however, their arrival raises a related question: if a consolidated post-trade view becomes available at a regulated cost, the commercial value of proprietary post-trade feeds shifts. Whether that shift reaches into pre-trade and non-display tariffs will depend on the design choices still in play.
Post-trade: the consensus unfinished business
If there was a single area where panellists converged from genuinely different positions, it was post-trade. The lack of interoperability at the CSD and CCP layers was identified across the table as the most concrete piece of unfinished competitive infrastructure. Interoperability exists in pockets but not as a general property of the European post-trade landscape, and the cost reductions that competition has delivered at the venue layer have not followed through – particularly acute in instruments such as ETFs, where settlement complexity compounds the problem.
One panellist confirmed that interoperability in Spanish clearing is opening up next year. Beyond that, the post-trade space has seen little structural innovation in recent years. The European clearing landscape remains substantially siloed, and the absence of CCP interoperability across the major markets continues to lock in incumbent advantages that the trading layer has, at least partially, eroded. Whether the regulatory appetite exists to push the question to the same degree as MiFID pushed the execution question is currently unclear.
The dissolving value chain
Another strand of the discussion turned to what the competitive reshaping has done to roles within the value chain. The clean delineation that prevailed two decades ago – buy-side to sell-side to exchange to market-maker – has dissolved. The buy-side now interacts directly with electronic liquidity providers and systematic internalisers; market-makers have moved towards facing clients directly; brokers have built their own MTFs; exchanges find themselves competing with the SIs that were historically downstream of them.
One panellist suggested that this has reorganised value rather than removed it: differentiation now lies in unique liquidity – bilateral workflows within MTF wrappers, block functionality, retail flow that institutional algos can interact with – and in absorbing connectivity complexity for smaller participants through white-labelled algo stacks. Another pointed out that the membership and listings franchise still matters: primary exchanges drive listings, listings drive trading, and the reputational and regulatory standing of a primary listing venue is not interchangeable with the technical capacity of an MTF or an SI. Price formation still happens predominantly on primary venues – cited as around 70% of European equity price-setting activity – with the rest of the market structure referencing those prices through PBBO, EBBO and midpoint mechanics. Unique liquidity matters here too: one continental dark pool, on the panel’s account, sees around 20% of its volume interacting with participants connected to no other venue.
A separate question, raised but left unanswered, concerned the data practices of systematic internalisers – whether users of SI services understand how the data generated by their flow is cross-utilised within the firms that provide those services.
Retail: the consensus closing note
If the panellists disagreed on where competition has failed, they agreed on where the next opportunity lies. Retail flow was identified as the most material untapped source of liquidity for European venues. One panellist cited markout differences of between two and ten basis points, depending on the liquidity bucket, between trades executed against the average market participant and trades executed against retail or local participants – an improvement that would, if scaled, materially improve execution outcomes across the central limit order book.
Retail flow is currently concentrated in the order books of a small number of neo-brokers, whose client bases include a large cohort of crypto-active investors now looking to expand into other asset classes. The competitive question for European venues – particularly those operating pan-European MTF licences – is how to design products that bring this flow onto regulated infrastructure without fragmenting liquidity between tokenised and conventional asset classes. Work is, on the panel’s account, under way.
Where this leaves the next phase
The picture that emerged was not one of competition unfulfilled but of competition redirected. The execution layer is fragmented, in some respects more than is useful. The market data layer has become a primary site of competitive contest, with revenue dynamics the original regulatory architecture did not anticipate. The internalisation layer has grown into a quiet structural force the public-market framing does not fully capture. The post-trade layer remains substantially intact in its pre-competitive form. The next phase of European market structure policy may therefore need to address the data and post-trade layers with the seriousness that MiFID brought to execution two decades ago.
The opening question of the panel was whether the promise of competition has been broken. The more useful question, on the evidence of the discussion that followed, is whether the promise was specified clearly enough in the first place.
Subscribe to our newsletter
