About a-team Marketing Services
The knowledge platform for the financial technology industry

A-Team Insight Blogs

Tumbling Down the Rabbit Hole

Subscribe to our newsletter

By Christian Voigt, Senior Regulatory Adviser at Fidessa

With much of the MiFID II Level 2 text close to being finalised, the markets continue to dive even deeper into the details and home in on Level 3 material, such as the Q&As and ESMA guidelines.

One such detail lies in the phrase “traded on a trading venue” which is used in MiFIR to define instrument scope for topics such as pre- and post-trade transparency, systematic internaliser, trading obligation and transaction reporting across derivatives and equities. For instance, the trading obligation (i.e. requirement to trade on-exchange) covers all shares traded on a trading venue. How can a broker bound by the rules of MiFID II execute non-EU stocks if those stocks also happen to be traded on venues within the EU? As the Fidessa Fragulator shows, around 0.15% of trading in Apple’s stock is conducted on EU exchanges and is therefore potentially in scope of the MiFIR trading obligation. But what of the other 99.85% of Apple liquidity, how is that to be treated? Will non-EU venues all become recognised as equivalent under MiFID II or will non-EU trading be classed as OTC and become inaccessible to any EU broker? The latter would severely restrict brokers in their quest for best execution.

With financial institutions and regulators heading deeper down the rabbit hole by focusing on the minutiae of some of the most technical issues of MiFID II, some might start to ask what kind of wonderland awaits us post-implementation.

Subscribe to our newsletter

Related content

WEBINAR

Recorded Webinar: The Buy-side Trading Desk of the Future

The buy-side trading desk is facing a structural reckoning. Decades of siloed systems for equities, FX and fixed income have created what COOs increasingly describe as a “silo tax” – duplicated headcount, fragmented data, and operational overhead that is harder to justify now that the underlying workflows have, in functional terms, converged. Thirty years of...

BLOG

Bloomberg Brings Electronic Trading to ABS, Fixed Income’s Last Holdout

Bloomberg’s launch of an electronic trading workflow for asset-backed securities, announced earlier this month, lands in an asset class that has resisted automation longer than most of fixed income. The list-based process, now being rolled out to clients across the US and EMEA, is built around the Bids Wanted in Competition and Offers Wanted in...

EVENT

TEST Event page 1

Now in its 15th year the TradingTech Summit London brings together the European trading technology capital markets industry and examines the latest changes and innovations in trading technology and explores how technology is being deployed to create an edge in sell side and buy side capital markets financial institutions.

GUIDE

Regulatory Data Handbook 2026 – Fourteenth Edition

Welcome to the fourteenth edition of A-Team Group’s Regulatory Data Handbook. Supervisors increasingly expect firms to demonstrate which rules apply, which data supports each obligation, who owns the control and how exceptions are identified and resolved. Policies and implementation programmes must now be supported by records that can withstand regulatory scrutiny. This edition examines material...