RTS27 and 28

RTS 27 and 28 – The 2024 Status of These Reports in UK and EU

With the separation of EU and UK requirements and the beginning of divergence, determining whether your firm needs to complete RTS 27 and 28 reports can be very confusing.  We summarise the current status of each report across both regimes.


How Does a Regulator or ARM Ascertain MiFIR Reportability?

The current application of MiFIR requires both the regulators and ARMs to filter through vast quantities of data to determine which transactions should be reported.  Trading venues and systematic internalisers (SIs) are obliged to submit reference data for financial instruments to ESMA to be published in FIRDs. This is outlined in Article 27 of MiFIR and Article 4 of Market Abuse Regulation (MAR).


How Do Public Holidays and Bank Holidays Impact Trade Reporting?

Public holidays and bank holidays can have a major impact on trade and transaction reporting requirements; especially if you are an entity operating under multiple regimes.  

When there is a public holiday where the regulatory body (or regulated entity) is located, it is likely that the timing of report submissions will be extended commensurately.

Best Execution

Payment for Order Flow (PFOF)

PFOF is a form of compensation that a brokerage firm receives for directing orders for trade execution to a particular market maker or exchange. Wholesale market makers have leveraged the almost exclusive use of electronic trading by retail investors to pay brokerages for the right to execute orders coming from their clients.