Last year, we published a blog highlighting that amendments to MiFIR and MiFID II went into force, beginning the process of establishing a consolidated tape for prices and volumes of securities traded on EU trading venues. Since then, more changes have been introduced in the MiFIR Review amendments, which represent a substantial transformation in EU financial markets regulation. Aimed at bolstering market transparency, refining reporting obligations, and ensuring a level playing field for investors, these reforms introduce pivotal changes that market participants must address proactively. Firms that proactively adapt to these changes will be better positioned to maintain compliance and capitalize on new opportunities with confidence.
Key Changes Under MiFIR Review
1. Introduction of the Consolidated Tape (CTP):
MiFIR Review mandates the establishment of a Consolidated Tape Provider (CTP) to aggregate post-trade data across EU trading venues, initially focusing on bonds, with plans to extend to equities and ETFs (European Commission, 2023). This initiative seeks to enhance price transparency further and mitigate market fragmentation.
2. Enhanced Pre- and Post-Trade Transparency Requirements:
MiFIR imposes pre- and post-trade transparency requirements for a wide range of financial instruments, including equities, bonds, structured finance products, emission allowances, and derivatives. MiFIR Review refines this existing regime to improve consistency, data quality, and readiness for the introduction of the consolidated tape (European Commission, 2023; ESMA, 2024). This rationalization includes standardizing deferral regimes, updating reporting fields, and introducing static thresholds to classify instruments as liquid or determine when transactions qualify as large-scale.
3. Market Data Cost Reforms:
Addressing concerns over rising market data costs, MiFIR Review enforces the provision of market data on a reasonable commercial basis, compelling trading venues and Approved Publication Arrangements (APAs) to justify their pricing structures and ensure non-discriminatory access to information (European Commission, 2023).
4. Revised Best Execution Requirements:
MiFIR Review introduces new rules for how firms must establish and assess the effectiveness of their order execution policies. While MiFID II already required firms to implement policies aimed at achieving the best possible results for clients, the updated technical standards provide more explicit guidance on what those policies should include and how their effectiveness should be evaluated over time (European Securities and Markets Authority, 2025b).
Firms must now adopt a more structured approach to venue selection, execution quality monitoring, and internal governance. The goal is to promote greater consistency in how best execution is applied across firms and ensure clients receive transparent, measurable outcomes.
Implications for Financial Firms
The MiFIR Review regulatory amendments require significant operational and strategic adjustments, particularly in compliance, trading, and data management functions. Firms must be able to interpret complex transparency rules in real time and adapt their reporting systems to reflect new consolidated tape and deferral structures (European Parliament, 2024; European Securities and Markets Authority, 2025a).
Failure to comply could expose firms to financial penalties and reputational risks, particularly at a time when EU supervisors are intensifying market surveillance and enforcement actions.
Where Droit Can Help
Droit’s pre- and post-trade solutions offer a comprehensive way to navigate the additional complexities introduced by the MiFIR Review:
- Real-Time Regulatory Decision-Making: Our patented Adept platform automates the determination of reporting obligations, ensuring accurate and timely compliance with evolving transparency requirements.
- Continuous Rule Management: Droit continuously updates its regulatory logic to reflect the latest ESMA guidelines and technical standards, empowering compliance teams to manage change more effectively.
- Seamless Cross-Jurisdictional Compliance: We provide a unified framework to manage regulatory obligations across multiple jurisdictions, facilitating seamless compliance in a global trading environment.
Droit stands ready to support your firm in this transition, offering the tools and expertise necessary to navigate the evolving regulatory landscape. Need help implementing new requirements under MiFIR Review? Click here to schedule a call with a solutions expert from our team.
- European Commission. (2023, June 30). Commission welcomes political agreement on the review of the Markets in Financial Instruments Regulation. Retrieved from https://finance.ec.europa.eu/news/commission-welcomes-political-agreement-review-markets-financial-instruments-regulation-2023-06-30_en
- European Parliament. (2024, January 16). Amendments to the Markets in Financial Instruments Regulation (MiFIR). Retrieved from https://www.europarl.europa.eu/doceo/document/TA-9-2024-0004_EN.html
- European Securities and Markets Authority. (2024). MiFID II and MiFIR review. Retrieved from https://www.esma.europa.eu/trading/mifid-ii-and-mifir-review
- European Securities and Markets Authority. (2025b). Final Report on the Technical Standards on firms’ order execution policies under MiFID II. Retrieved from https://www.esma.europa.eu/sites/default/files/2025-04/ESMA35-335435667-6253_Final_Report_-_MiFID_II_RTS_on_order_execution_policies.pdf