ESMA Q&A Update – MiFID II and MiFIR Market Structures


MiFID II and MiFIR commodity derivatives


16 December 2022


Level of significance of change


Main points

An investment firm acting as a single liquidity provider (LP) on a Regulated Market (RM) and/or a Multilateral Trading Facility (MTF), is able to operate a System Internaliser (SI) only if the two activities are fully separated. This is due to potential conflict of interest when the investment firm have access to order book information when acting as an LP.

How does this change my reporting?

There is no impact on trade reporting.

What do I need to do?

No reporting changes necessary.


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