In light of the MiFIR/MiFID II review (entered into force on 28 March 2024, with transposition deadlines for MiFID II amendments set on 29 September 2025), this consultation package no 3 addresses key aspects of equity market transparency, focusing on proposed technical standards and amendments to existing regulations.
While BETTER FINANCE recognises the importance of this consultation, we note that its highly technical nature limits the ability of retail investors to provide direct, actionable feedback, as it primarily targets market operators (data providers, investment firms, venues, etc.). The complexity of the regulatory changes makes it challenging for retail stakeholders to fully engage. Nonetheless, we support ESMA’s overarching goal to enhance transparency, efficiency, and competitiveness in EU financial markets, as outlined in the MiFIR/D Level 1 review.
Our feedback focuses on the following key areas:
Equity Transparency (RTS 1): Proposed amendments to improve pre-trade and post-trade transparency for equity instruments (e.g. shares, ETFs). The goal is to clarify data reporting standards and improve the assessment of liquidity.
Consolidated Tape Providers (CTP) – Input/Output Data Standards (RTS 8): New technical standards for the equity consolidated tape aim to enhance post-trade transparency. This would provide retail investors and other market participants with more reliable, actionable market data for better-informed decisions, particularly regarding liquidity and market depth across order books.
Flags under RTS 2: A review of the current flagging system, particularly for Systematic Internalisers (SIs), aims to improve clarity and relevance, offering more precise information about liquidity and transaction types.
The inputs provided to this consultation will help ESMA in shaping final technical standards for equity-related provisions that are ti be susmited to the European Commission by December 2024.
Key BETTER FINANCE Feedback
BETTER FINANCE remains committed to protecting retail investors’ interests by advocating for transparency, access to market data, and accurate price formation in equity markets. This consultation response ensures that the proposed amendments and technical standards introduced in the MiFIR review align with the goals of fostering a transparent and consumer-friendly financial market.
Central to BETTER FINANCE position is ensuring that retail investors are not disadvantaged when accessing liquidity data, price formation mechanisms, and execution conditions – particularly to enable regulators and investors' assessment of optimal 'best execution' outcomes was achieved from their brokers. The feedback emphasises the importance of pre-and post-trade transparency, granular data reporting, and protection for retail investors in a dynamic and evolving financial landscape.
⬇️ Read the full consultation response ⬇️