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The objectives of MiFID II are to increase market transparency, efficiency and safety by bringing the majority of non-equity products into a robust regulatory regime and moving a significant part of OTC trading onto regulated platforms.

MiFID II Level 2

MiFID II will bring much of the transparency traditional in equity markets to bond trading. Europe will go further with bond transparency rules than just about anywhere in the world, including the US. MiFID II’s regulatory regime brings into effect pre-trade transparency for bonds as well as post-trade. This will result in a significant impact on the market structure of bond markets. Bond pre-and post-trade transparency requirements will be calibrated for different types of bond market trading structures such as order-book, quote-driven, hybrid and periodic auction trading systems. In order to calibrate bonds correctly for MiFID II transparency obligations, IT systems have to be enhanced, developed or built from scratch. This is a major undertaking for the industry. Banks, regulators and investors are dependent on data collected to meet MiFID II’s commitments.

Owing to the need for an IT build both by National Competent Authorities and by the industry, MiFID II has been delayed by one year and is set to take effect on 3rd January 2018. 

MiFID II expected timeline:

ESMA expected to publish further Q&As to assist market participants in understanding the legislation in the run up to the entry into force of Level 2 text on 3rd January 2018.

July 2017
Due to the 12 month delay to MiFID II agreed in June 2016, EU countries are due to transpose the new MiFID II directive into local laws by 3rd July 2017. Implementation was due to take effect 30 months from the entry into force following publication in the Official Journal of the European Union. As MiFID II is a directive, implementation will therefore take longer whilst some provisions of MiFIR will take effect immediately upon publication. However, both pieces of legislation are designed to work together.

January 2018
MiFID II and MiFIR are scheduled to enter into force on 3rd January 2018, following a 12 month delay agreed by legislators in June 2016 from the original date of 3rd January 2017.

MiFID II implementation: the Systematic Internaliser regime

A briefing note on ESMA Q&A on MiFID II Best Execution

Updated MiFID II/R and Repo Q&A
March 2017
A briefing note on ESMA’s final report on draft RTS for package orders

February 2017
Discussion paper on MiFID II Best Execution and Securities Financing Transactions

ERCC letter to the European Commission regarding the applicability of MiFID best execution to SFTs

December 2016
ESMA Consultation Paper on Consolidated Tape – ICMA Submission

November 2016
ICMA ‘FAQ’ on systematic internalisers for bond markets

A briefing note on systematic internalisers for bond markets

October 2016
SFT Reporting Requirements

September 2016
MiFID II/R Fixed Income Best Execution Requirements RTS 27 & 28

April 2016
MiFID II Transparency and Best Execution presentation (Q2 2016)

March 2016
ICMA response to FCA CP: Markets in Financial Instruments Directive II Implementation – Consultation Paper I Q6, 8, 12 and 13

MiFID II/MiFIR – Transparency & Best Execution requirements in respect of bonds - presentation Q1 2016

15 June 2015
JAC response to ESMA Consultation Paper - Draft guidelines on complex debt instruments and structured deposits (item 40 on the ICMA retail structured products webpage)

2 March 2015
ICMA responded to an ESMA Consultation Paper on MiFID II/MiFIR


Level 1:
Markets in Financial Instruments (MiFID II) - Directive 2014/65/EU
Markets in Financial Instruments (MiFIR) - Regulation (EU) No 600/2014

Level 2:
Overview and state of play of RTS and ITS relating to MiFID/MiFIR
ESMA – Policy activities related to MiFID (II) and MiFIR  

RTS 2: Transparency requirements for trading venues and investment firms in respect of bonds, structured finance products, emission allowances and derivatives
Annex to RTS 2

RTS 27: Best Execution – Reporting criteria
Annex to RTS 27

RTS 28: Best Execution – Quality of execution
Annex to RTS 28

Level 3:
2 February 2017 (ESMA70-1861941480-56) - Q&A on MiFIR data reporting

31 January 2017 (ESMA70-872942901-35) - Q&A on MiFID II and MiFIR transparency topics     
  • The systematic internaliser regime [Last update: 31/01/2017]
  • Pre-trade transparency waivers [Last update: 19/12/2016]
31 January 2017 (ESMA70-872942901-38) - Q&A on MiFID II and MiFIR market structures topics
  • Data disaggregation [Last update: 18/11/2016]    
  • Multilateral systems [Last update: 31/01/2017]    
16 January 2017 (ESMA00-6-265) - Briefing note on MiFID II technical data reporting requirements

17 November 2015 (2015/1514) - Note on MiFID-MiFIR implementation delays

See also:


Liz Callaghan
Director, Market Practice and Regulatory Policy; Secretary to the ICMA Secondary Market Practices Committee
Direct line: +44 20 7213 0313

Andy Hill
Senior Director, Market Practice and Regulatory Policy; secretary to the ICMA Secondary Market Practices Committee.
Direct line: +44 20 7213 0335

Gabriel Callsen
Associate, Market Practice and Regulatory Policy

Direct line: +44 20 7213 0334