EU MiFIR/MiFID II Review

Executive Summary

In 2021, the European Commission published a proposal for a regulation amending the Markets in Financial Instruments Regulation (MiFIR) and proposal for a directive amending the Markets in Financial Instruments Directive II (MiFID II) – the ‘MiFIR/MiFID II Review’. The proposals were part of the European Commission’s Capital Markets Union legislative package also amending the Alternative Investment Fund Managers Directive, the European Long-Term Investment Fund Regulation and introducing a European Single Access Point for public financial and sustainability-related data.

On 29 June 2023, the European Parliament and the Council of the EU reached a provisional political agreement in respect of the three main political issues under the MiFIR/MiFID II Review – inclusion of pre-trade data in a CT for shares and exchange-traded funds (ETFs); ban on Payment For Order Flow (PFOF); and provisions relating commodity derivatives. Following further discussions relating to changes to transparency waivers and deferrals, the derivatives trading regime, the systematic internaliser regime, the deletion of RTS 28 best execution reporting requirements and the design of the consolidated tape for bonds, the final texts of the Regulation amending MiFIR and Directive amending MiFID II were approved by the Council of the EU and European Parliament and published in the Official Journal of the EU on 8 March 2024.

The new Regulation amending MiFIR and the new Directive amending MiFID II took effect on 28 March 2024. The MiFIR Review is binding in its entirety and directly applicable in all Member States. Members States had until 28 September 2025 to transpose the MiFID II Review.

Most of the Level 1 reforms are now in application and a substantial part of ESMA's 'Level 2' work has been completed. This page provides an overview of the key changes relevant to AIMA members, identifies the main requirements that are already in effect and highlights the areas that remain relevant for firms to monitor.

Please contact Adam Jacobs-Dean or Aniqah Rao with any questions regarding the EU MiFIR/MiFID II Review.

Adam Jacobs-Dean

Managing Director, Global Head of Markets, Governance and Innovation
Aniqah Rao

Associate Director, Markets, Governance and Innovation

Key Amendments in Force

A number of the key reforms under the MiFIR/MiFID II Review are now operational. Below we provide a summary of the key changes.

Best Execution reporting

The MiFID II Review removed the requirement for investment firms to publish RTS 28 best execution reports set out under Article 27(6) of MiFID II. It also removed the obligation for execution venues to produce execution quality reports consistent to the format prescribed under RTS 27.

The reform was accompanied by ESMA's earlier decision to deprioritise supervisory action in relation to RTS 28 reporting while the legislative amendments were being completed.

The removal of RTS 28 reporting should not be understood as removing firms' broader best execution obligations. Firms remain subject to the applicable MiFID II requirements concerning best execution and order execution policies.

Designated Publishing Entity regime

The MiFIR Review replaced the previous mandatory systematic internaliser regime for the purposes of post-trade reporting with a Designated Publishing Entity (DPE) framework.

The DPE regime became operational on 3 February 2025. The mandatory SI regime ceased to apply from 1 February 2025, although firms may continue to opt into the SI regime. The quarterly publication of SI data was continued with immediate effect.

Under the DPE framework, an investment firm may be designated by its national competent authority as a DPE for particular classes of financial instruments. A DPE that is party to a transaction is responsible for making the transaction public through an approved publication arrangement.

Firms should therefore ensure that their arrangements for determining and allocating post-trade publication responsibilities reflect the DPE framework.

The ESMA DPE register provides the public record of firms designated for particular classes of financial instruments.

Single Volume Cap

The previous double volume cap mechanism (4% and 8%) has been replaced with a single 7% volume cap applying to trades executed under the reference price waiver or the negotiated trade waiver. The revised mechanism is now part of the EU transparency framework and firms should use the current ESMA transparency and volume-cap information when assessing the availability and use of relevant waivers.

Share Trading Obligation

The MiFIR Review amended the Share Trading Obligation (STO) in Article 23 of MiFIR.

The revised framework removes the previous condition that, for the STO to apply, shares had to be admitted to trading on a regulated market or traded on an EU trading venue. The Review also removes the previous specific exception for trades that were “non-systematic, ad-hoc, irregular and infrequent”. In addition, the revised STO provides an exception for shares traded on a third-country venue in the local currency or in a non-EEA currency.

Investment firms should review their existing STO assessments and controls to ensure that they reflect the revised scope and exceptions.

Payment for order flow

The MiFIR Review introduced a prohibition on receiving payment for order flow (PFOF).

A temporary exemption was available to certain Member States where investment firms were already receiving PFOF before 28 March 2024. That exemption could only apply until 30 June 2026. The temporary exemption has now expired. Firms should therefore assess any arrangements involving payments, commissions or non-monetary benefits connected with the execution or forwarding of client orders against the prohibition in Article 39a MiFIR.

Position management controls and position reporting for commodity derivatives and emission allowances

The MiFIR Review amended the framework for commodity derivatives and derivatives of emission allowances.

Position management controls have been extended to trading venues that trade derivatives on emission allowances. The Review also changes the scope of position reporting. Emission allowances (spot) are excluded from the position-reporting requirements, while position reporting for commodity derivatives and derivatives of emission allowances is enhanced. For trading venues where options are traded, the revised framework requires two weekly position reports, one of which excludes options.

Firms active in commodity derivatives or derivatives on emission allowances should review their position-reporting arrangements and related data processes.

New identifying reference data for OTC derivatives

The MiFIR Review introduces changes to the identification of OTC derivatives for the purposes of the transparency regime.

Under the revised Article 27 framework, identifying reference data for OTC derivatives are to be based on a globally agreed unique product identifier together with other relevant identifying reference data. Commission Delegated Regulation (EU) 2025/1003 establishes identifying reference data for OTC interest rate swaps and OTC credit default swaps. The required information includes, among other things, the asset class, instrument type, underlying asset type, notional currency and delivery type. The regulation also requires the ISO 4914 Unique Product Identifier (UPI) to be included in the identifying reference data for OTC interest rate swaps and OTC credit default swaps. These identifying reference data requirements applied from 1 September 2026.

Firms involved in the trading, reporting or publication of in-scope OTC derivatives should ensure that their data and reporting arrangements can accommodate the new identifying reference data requirements. The new OTC derivative identifier requirements should be considered alongside the revised MiFIR transparency regime, including the changes to the transparency treatment of OTC derivatives.

Further MiFIR/MiFID II Review measures and implementation

A number of the MiFIR/MiFID II Review measures are now in force or operational, but implementation of the Review is still underway through a series of Level 2 measures and phased implementation dates. The table below sets out the remaining measures in more detail.

Article	Description	Application Date	Resources
MiFIR Review Article 26	European Commission delegated act specifying the identifying reference data to be used for OTC derivatives for the purposes of the transparency requirements under Article 8a(2) and Articles 10 and 21 MiFIR. The European Commission consulted on the proposed OTC derivatives identifier and reference-data framework in two stages. The first targeted consultation closed on 9 January 2024, followed by a second consultation which closed on 10 July 2024. The Commission adopted the Delegated Act on 24 January 2025. Commission Delegated Regulation (EU) 2025/1003 was subsequently published in the Official Journal on 22 May 2025 and entered into force on 11 June 2025. The Regulation specifies identifying reference data for OTC interest rate swaps and OTC credit default swaps, including the ISO 4914 Unique Product Identifier (UPI). The specified data includes, among other things, asset class, instrument type, underlying asset type, notional currency and delivery type. Firms involved in the trading, reporting or publication of in-scope OTC derivatives should ensure that systems and data processes can accommodate the UPI and associated identifying reference data. Firms should also consider the interaction with the revised derivatives transparency regime, which is due to apply from 1 March 2027. ESMA's derivatives transparency Final Report expressly links the new OTC identifier framework with the future transparency regime.	1 September 2026. From that date, the specified identifying reference data and ISO 4914 UPI are required for the relevant transparency purposes.	European Commission first consultation (closed 9 January 2024) AIMA response to first European Commission consultation European Commission second consultation (closed 10 July 2024) European Commission Delegated Act (adopted)
MiFIR Review Article 11	RTS specifying deferred publication in respect of bonds, structured finance products or emission allowances. The MiFIR Review revised the framework for post-trade transparency and deferrals for non-equity instruments. ESMA consulted on the amendments to RTS 2 as part of its May 2024 consultation package, with a supplementary consultation in September 2024. ESMA submitted its Final Report to the European Commission on 16 December 2024. The European Commission adopted the relevant Delegated Act on 18 June 2025. It was published in the Official Journal on 3 November 2025. The amendments form part of the broader revision of RTS 2 and the non-equity transparency framework. ESMA has also updated its reporting systems to reflect the revised transparency calculations and reporting requirements. Firms subject to non-equity transparency requirements should ensure that instrument classification, liquidity assessments, deferral logic, publication arrangements and related reference-data processes reflect the revised RTS.	The revised requirements apply on a phased basis, including application dates of 23 November 2025 and 2 March 2026 for different provisions.	ESMA main consultation and supplementary consultation (closed 28 August 2024 and 15 September 2024, respectively) AIMA summary of ESMA main consultation AIMA summary of ESMA supplementary consultation AIMA response to ESMA main consultation [No AIMA response to ESMA supplementary consultation] ESMA Final Report European Commission Delegated Act (adopted) Annexes to Delegated Act (adopted)
MiFIR Review Article 12 -	RTS specifying the obligation to make pre-trade and post-trade data available on a reasonable commercial basis. The MiFIR Review strengthened the framework governing the provision of market data on a reasonable commercial basis. ESMA consulted on the new RTS as part of its May 2024 consultation package. ESMA submitted its Final Report to the European Commission on 16 December 2024. The European Commission adopted the Delegated Act on 12 June 2025, and it was published in the Official Journal on 3 November 2025. The new RTS entered into force on 23 November 2025. Market-data providers authorised before that date benefited from a transition period for existing contractual arrangements until 22 August 2026. Market-data providers should have reviewed pricing methodologies, cost allocation, margins, contractual arrangements and supporting documentation against the new RCB requirements. Market-data users should consider whether changes to pricing and licensing arrangements affect their data procurement arrangements.	23 November 2026	ESMA consultation (closed 28 August 2024) AIMA summary of ESMA consultation AIMA response to ESMA consultation ESMA Final Report European Commission Delegated Act (adopted) Annexes to Delegated Act (adopted)
MiFIR Review Article 22	RTS specifying the quality of data transmitted to consolidated tape providers (CTP), measures to address erroneous trade reporting and enforcement standards in relation to data quality, including arrangements regarding cooperation between data contributors and the CTP and, where necessary, the quality and the substance of the data for the operation of the consolidated tapes. ESMA consulted on the CTP framework as part of its May 2024 consultation package, with a supplementary consultation in September 2024. ESMA submitted its Final Report to the European Commission on 16 December 2024. The Commission subsequently adopted the relevant CTP technical standards. These cover the data to be supplied to CTPs, data quality and related operational requirements. The CTP framework is now moving from legislative implementation into operational rollout. ESMA has issued Q&As addressing the onboarding of data contributors and has reminded trading venues and APAs that they have legal obligations to contribute data from the relevant CTP go-live. ESMA expects contributors to engage with selected CTPs ahead of formal authorisation and to undertake connectivity and end-to-end testing.	23 November 2026	ESMA main consultation and supplementary consultation (closed 28 August 2024 and 15 September 2024, respectively) AIMA summary of ESMA main consultation AIMA summary of ESMA supplementary consultation AIMA response to ESMA main consultation [No AIMA response to ESMA supplementary consultation] ESMA Final Report European Commission Delegated Act specifying input and output data, synchronisation of business clocks and revenue distribution for shares and ETFs (adopted) Annexes to Delegated Act specifying input and output data, synchronisation of business clocks and revenue distribution for shares and ETFs (adopted) European Commission Delegated Act regarding standard forms, procedures for the authorisation of APAs, ARMs and CTPs and related notifications (adopted) Annexes to Delegated Act regarding standard forms, procedures for the authorisation of APAs, ARMs and CTPs and related notifications (adopted) ** ESMA consultation on amendment of input and output data of CTPs - specific data fields relevant to the derivatives CTP only (closes 3 July 2025)
MiFIR Review Article 22	RTS specifying the level of accuracy to which business clocks used for recording the date and time of reportable events are to be synchronised. The business-clock requirements were developed as part of the CTP Level 2 package. The European Commission adopted the relevant Delegated Act on 12 June 2025, with publication in the Official Journal on 3 November 2025. Commission Delegated Regulation (EU) 2025/1155 specifies the input and output data for consolidated tapes, synchronisation of business clocks and revenue redistribution for shares and ETFs. ESMA has issued Q&As clarifying, among other matters, the timestamp requirements for data transmitted to CTPs.	The provisions relating to business-clock synchronisation applied from 2 March 2026, with further CTP provisions applying from 23 November 2026.
MiFIR Review Article 28	RTS specifying the information to be provided by applicant CTPs to ESMA and the information to be included in the notifications as regards CTPs. The MiFIR Review established the framework for the authorisation and supervision of CTPs. ESMA's December 2024 Final Report covered the relevant Level 2 requirements. The Commission subsequently adopted the technical standards concerning standard forms and procedures for the authorisation of APAs, ARMs and CTPs. Firms involved in CTP data contribution should monitor the relevant CTP authorisation and go-live timetable for each asset class rather than assuming a single EU-wide implementation date.	The CTP regime is being implemented separately by asset class. ESMA selected EuroCTP as the equities CTP in December 2025 and authorised it on 27 July 2026. EuroCTP was given a transition period until 30 September 2026 to complete operational and technical arrangements. ESMA also selected Etrading Software as the OTC derivatives CTP in July 2026.
MiFIR Review Article 28 =	ITS specifying the standard forms, templates and procedures for the information to be provided by applicant CTPs for authorisation	23 November 2026
MiFIR Review Article 32 -	RTS specifying the weight assigned to each CTP revenue redistribution scheme crtierion, the method for calculating the amount of the revenue to be redistributed to data contributors, the criteria under which the CTP can suspend temporarily the participation of that data contributor in the revenue redistribution scheme and the conditions under which the CTP is to resume revenue redistribution and, where there was no breach of the CTP's requirements, provide that data contributor with the revenue retained plus interest. The revenue redistribution framework was developed alongside the wider CTP Level 2 package. ESMA submitted its Final Report on 16 December 2024 and the Commission subsequently adopted the relevant technical standards.	23 November 2026 for the relevant provisions. Implementation linked to CTP operational rollout.
MiFIR Review Article 3	amended RTS 1 and Technical Advice on the liquidity assessment for equity instruments and on equity transparency (specifying the details of pre-trade data to be made public for classes of financial instruments). The Review amended the equity transparency framework, including requirements relating to pre-trade transparency information and the determination of the most relevant market in terms of liquidity. ESMA consulted on the changes in its 2024 Level 2 consultation package and submitted its Final Report in December 2024. The European Commission adopted the relevant Delegated Act on 18 June 2025, with publication in the Official Journal on 3 November 2025. Firms should review equity instrument liquidity classifications, transparency calculations, pre-trade data requirements and the identification of the most relevant market in terms of liquidity.	Certain provisions applied from 2 March 2026, with further provisions applying from 23 November 2026. ESMA has already implemented related changes to its transparency reporting systems. From April 2026, ESMA's reporting framework was updated to reflect the revised RTS 1 and RTS 2 calculations.	ESMA consultation (closed 15 September 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report European Commission Delegated Act (adopted) Annexes to Delegated Act (adopted)
MiFID II Review Article 4	RTS specifying the criteria to be taken into account in establishing and assessing the effectiveness of investment firms’ order execution policies. ESMA consulted on the proposed RTS in 2024 and submitted its Final Report to the European Commission on 10 April 2025. The Commission has endorsed the RTS through Commission Delegated Regulation (EU) 2026/825, adopted on 14 April 2026 and published in the Official Journal on 23 July 2026. It entered into force on 12 August 2026. The Regulation repeals the existing RTS 27 and RTS 28 delegated regulations and introduces detailed requirements concerning order execution policies and their ongoing assessment. The new requirements include, among other things: the factors and criteria firms must consider when selecting execution venues; the use of reference data, including consolidated tape data where available; treatment of automatic order-routing systems; specific client instructions; execution when dealing on own account; monitoring of the effectiveness of the order execution policy; quantitative thresholds for assessing execution quality; annual assessment of the effectiveness of the policy; and additional assessments following material changes or identified deficiencies. Firms should now begin a detailed gap analysis against the final RTS rather than waiting until 2028. This should cover order execution policies, venue selection, execution-quality monitoring, reference data, automatic routing, OTC execution and governance/annual review processes.	12 February 2028. The 18-month period between entry into force and application is intended to give firms time to adjust their policies, procedures and IT infrastructure.	ESMA consultation (closed 16 October 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFID II Review Articles 10 - 11	RTS on position management controls, ITS 4 on the format of position reports by investment firms and market operators and Technical Advice on position reporting thresholds. ESMA consulted on the changes in May 2024 and submitted its Final Report to the European Commission on 16 December 2024. The Review extends position-management controls to trading venues trading derivatives on emission allowances and makes changes to position reporting, including the exclusion of spot emission allowances and enhanced reporting arrangements. The original implementation timetable anticipated Commission adoption of the position-management RTS in Q4 2025 and ITS 4 in Q1 2026. The technical implementation has since progressed. ESMA confirmed on 14 August 2026 that the new weekly commodity derivatives position-reporting framework would go live on 3 September 2026. Market participants must submit weekly position reports using the updated requirements, technical specifications and XML Schema v2.0. Firms subject to position reporting should ensure that reporting arrangements, data mappings, validation and controls have been updated to the current technical specifications.	Q4 2025: Expected final EC RTS on position management controls for commodity derivatives Q1 2026: Expected final EC ITS 4 on position reporting in commodity derivatives	ESMA consultation (closed 23 August 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFIR Review Article 4	RTS specifying the method, including the flagging of transactions, by which it collates, calculates and publishes the transaction data, to provide an accurate measurement of the total volume of trading per financial instrument and the percentages of trading that use the waiver under the single volume cap across the EU. The MiFIR Review replaces the former double volume cap with a single 7% volume cap. ESMA consulted on the relevant technical standards in 2024 and submitted its Final Report to the European Commission on 10 April 2025. The Final Report covers: the methodology for calculating the single volume cap; transparency calculations; the phasing out of certain daily reporting; the revised SI notification regime; and related circuit-breaker requirements.		ESMA consultation (closed 15 October 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFIR Review Article 7	RTS specifying waivers for bonds, structured finance products, emission allowances, derivatives and package orders. The Review changes the waiver framework for pre-trade transparency and introduces specific provisions concerning derivatives and package orders. ESMA consulted on the non-equity elements in 2024 and subsequently launched a further consultation on derivatives transparency and package orders in April 2025. ESMA published its Final Report on derivatives transparency, package orders and CTP input/output data in December 2025. The Final Report covers pre- and post-trade transparency for ETDs and OTC derivatives, the deferral regime and package orders. Firms trading derivatives should assess the proposed impact on pre- and post-trade transparency, waiver eligibility, package-order treatment and deferrals.	ESMA Final Report completed; Commission Level 2 process ongoing. ESMA's final proposals envisage application of the revised derivatives transparency framework from 1 March 2027, subject to completion of the Commission adoption process.	ESMA consultation (closed 28 August 2024 - for bonds, SFPs and emission allowances) [No AIMA response to August 2024 consultation] ESMA consultation - derivatives and package orders (closes 3 July 2025)
MiFIR Review Article 13	RTS specifying the minimum quote size of systematic internalisers. ESMA consulted on the revised SI requirements as part of its 2024 consultation package and submitted its Final Report on 10 April 2025. The Final Report formed part of ESMA's wider work on the revised SI notification regime, single volume cap and circuit breakers.	ESMA Final Report completed; Commission Level 2 process to be monitored.	ESMA consultation (closed 15 October 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFIR Review Article 14	ITS specifying the content and format of the notification for systematic internalisers. The MiFIR Review moves away from the previous quantitative SI assessment framework and introduces a revised notification approach. ESMA consulted on the revised notification requirements in 2024 and submitted its Final Report on 10 April 2025.
MiFIR Review Article 25	amended RTS 24 on the reporting of transactions to competent authorities (specifying the details and formats of the order data that trading venue operators are required to maintain and keep at the disposal of the national competent authorities for atleast five years). ESMA consulted on the review of RTS 24 alongside RTS 22 in late 2024. ESMA published its Final Report on RTS 22 and RTS 24 on 23 June 2025. The revised standards address the details and format of order data to be maintained by trading venue operators and available to competent authorities.	ESMA Final Report completed; Commission Level 2 process to be monitored.	ESMA consultation (closes 3 January 2025) AIMA summary of ESMA consultation
MiFIR Review Article 46	European Commission assessment of the possibility of extending the transaction reporting requirements under Article 26 MiFIR to AIFMs as defined in Article 4(1), point (b), of Directive 2011/61/EU, and management companies, as defined in Article 2(1), point (b), of Directive 2009/65/EC, which provide investment services and activities and which execute transactions in financial instruments. AIFMs and UCITS management companies should monitor this work separately from the RTS 22 implementation.	29 March 2025 *- delayed.* Commission assessment – monitor for further development.
MiFID II Review Article 7	recast RTS 7a on organisational requirements of trading venues, adding new provisions on circuit breakers and with targeted amendments to adapt to the DORA framework. ESMA consulted on the revised requirements in 2024 and submitted its Final Report to the European Commission on 10 April 2025. The Final Report covers circuit breakers alongside the revised SI notification regime and single-volume-cap methodology.	10 July 2025: Deadline for European Commission to decide whether to endorse ESMA's proposed amendments ESMA Final Report completed; Commission Level 2 process to be monitored.	ESMA consultation (closed 15 October 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFIR Review Article 10	RTS specifying deferred publication in respect of derivatives. The Review establishes a revised framework for post-trade transparency and deferrals for derivatives. ESMA consulted on the revised derivatives transparency framework in April 2025 and published its Final Report in December 2025. The Final Report addresses: pre- and post-trade transparency; liquidity determination; deferrals; package orders; and the interaction between the derivatives transparency framework and the OTC derivatives CTP. Firms should assess the proposed changes to deferral periods, transparency eligibility and the interaction with the new OTC derivative reference-data regime.	The revised derivatives transparency regime is expected to apply from 1 March 2027, subject to completion of the Level 2 process. ESMA Final Report completed; Commission adoption pending.	ESMA consultation (closes 3 July 2025)
MiFIR Review Article 25	RTS specifying financial instruments reference data. The revised RTS updates the reference-data requirements used for transparency and supervisory purposes. It also needs to be considered alongside the separate Commission Delegated Regulation on OTC derivatives identifying reference data.	*Q1 2025: Expected EC adoption of RTS 23* ESMA Final Report completed; implementation of the revised reference-data framework is progressing. The OTC derivative identifying-reference-data element is already operational from 1 September 2026 under Commission Delegated Regulation (EU) 2025/1003.	ESMA consultation (closed 28 August 2024) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFIR Review Article 26	amended RTS 22 on transaction data reporting (incl. the conditions for linking specific transactions and the means of identifying of aggregated orders resulting in the execution of a transaction; and the date by which transactions are to be reported). ESMA consulted on RTS 22 in late 2024. The consultation closed on 3 January 2025. ESMA published its Final Report on 23 June 2025, covering both RTS 22 and RTS 24. The revised RTS is intended to improve the quality and usefulness of transaction data while reducing unnecessary reporting complexity. Firms should undertake a systems impact assessment covering transaction-reporting fields, data sourcing, instrument identifiers, order identifiers, aggregation/linking requirements, reporting timing and reconciliation.	Q4 2025: Expected EC adoption of RTS 22 on Transaction Data Reporting ESMA Final Report completed; Commission Level 2 adoption/application to be monitored.	ESMA consultation (closed 3 January 2025) AIMA summary of ESMA consultation [No AIMA response] ESMA Final Report
MiFIR Review Article 33	RTS specifying the content, timing, format and terminology of the reporting obligation for CTPs to publish performance statistics and incident reports relating to data quality and data systems. The requirements form part of the wider CTP Level 2 package. ESMA submitted its Final Report on 16 December 2024, with the Commission subsequently adopting the relevant technical standards.	Adopted – implementation linked to CTP operational rollout.	See above rows on MiFIR Review Articles 22, 28 and 32
MiFIR Review Article 1	RTS specifying the monetary, foreign exchange and financial stability policy operations and the types of transactions to which the exemption from transparency requirements will not apply with regard to members of the European System of Central Banks which are not members of the Eurosystem. ESMA consulted on the measure as part of the April 2025 consultation package, with the consultation closing on 3 July 2025.	29 March 2026 Q4 2025: ESMA publication of Final Report and submission of RTS to the European Commission for adoption	ESMA consultation (closed 3 July 2025) [No AIMA response]

Article

Description

Application Date

Resources

MiFIR Review Article 26

European Commission delegated act specifying the identifying reference data to be used for OTC derivatives for the purposes of the transparency requirements under Article 8a(2) and Articles 10 and 21 MiFIR.

The European Commission consulted on the proposed OTC derivatives identifier and reference-data framework in two stages. The first targeted consultation closed on 9 January 2024, followed by a second consultation which closed on 10 July 2024.

The Commission adopted the Delegated Act on 24 January 2025. Commission Delegated Regulation (EU) 2025/1003 was subsequently published in the Official Journal on 22 May 2025 and entered into force on 11 June 2025.

The Regulation specifies identifying reference data for OTC interest rate swaps and OTC credit default swaps, including the ISO 4914 Unique Product Identifier (UPI). The specified data includes, among other things, asset class, instrument type, underlying asset type, notional currency and delivery type.

Firms involved in the trading, reporting or publication of in-scope OTC derivatives should ensure that systems and data processes can accommodate the UPI and associated identifying reference data. Firms should also consider the interaction with the revised derivatives transparency regime, which is due to apply from 1 March 2027. ESMA's derivatives transparency Final Report expressly links the new OTC identifier framework with the future transparency regime.

1 September 2026. From that date, the specified identifying reference data and ISO 4914 UPI are required for the relevant transparency purposes.

European Commission first consultation (closed 9 January 2024)

AIMA response to first European Commission consultation

European Commission second consultation (closed 10 July 2024)

European Commission Delegated Act (adopted)

MiFIR Review Article 11

RTS specifying deferred publication in respect of bonds, structured finance products or emission allowances.

The MiFIR Review revised the framework for post-trade transparency and deferrals for non-equity instruments. ESMA consulted on the amendments to RTS 2 as part of its May 2024 consultation package, with a supplementary consultation in September 2024.

ESMA submitted its Final Report to the European Commission on 16 December 2024.

The European Commission adopted the relevant Delegated Act on 18 June 2025. It was published in the Official Journal on 3 November 2025.

The amendments form part of the broader revision of RTS 2 and the non-equity transparency framework. ESMA has also updated its reporting systems to reflect the revised transparency calculations and reporting requirements.

Firms subject to non-equity transparency requirements should ensure that instrument classification, liquidity assessments, deferral logic, publication arrangements and related reference-data processes reflect the revised RTS.

The revised requirements apply on a phased basis, including application dates of 23 November 2025 and 2 March 2026 for different provisions.

ESMA main consultation and supplementary consultation (closed 28 August 2024 and 15 September 2024, respectively)

AIMA summary of ESMA main consultation

AIMA summary of ESMA supplementary consultation

AIMA response to ESMA main consultation

[No AIMA response to ESMA supplementary consultation]

ESMA Final Report

European Commission Delegated Act (adopted)

Annexes to Delegated Act (adopted)

MiFIR Review Article 12 -

RTS specifying the obligation to make pre-trade and post-trade data available on a reasonable commercial basis.

The MiFIR Review strengthened the framework governing the provision of market data on a reasonable commercial basis. ESMA consulted on the new RTS as part of its May 2024 consultation package.

ESMA submitted its Final Report to the European Commission on 16 December 2024.

The European Commission adopted the Delegated Act on 12 June 2025, and it was published in the Official Journal on 3 November 2025.

The new RTS entered into force on 23 November 2025. Market-data providers authorised before that date benefited from a transition period for existing contractual arrangements until 22 August 2026.

Market-data providers should have reviewed pricing methodologies, cost allocation, margins, contractual arrangements and supporting documentation against the new RCB requirements. Market-data users should consider whether changes to pricing and licensing arrangements affect their data procurement arrangements.

23 November 2026

ESMA consultation (closed 28 August 2024)

AIMA summary of ESMA consultation

AIMA response to ESMA consultation

ESMA Final Report

European Commission Delegated Act (adopted)

Annexes to Delegated Act (adopted)

MiFIR Review Article 22

RTS specifying the quality of data transmitted to consolidated tape providers (CTP), measures to address erroneous trade reporting and enforcement standards in relation to data quality, including arrangements regarding cooperation between data contributors and the CTP and, where necessary, the quality and the substance of the data for the operation of the consolidated tapes.

ESMA consulted on the CTP framework as part of its May 2024 consultation package, with a supplementary consultation in September 2024.

ESMA submitted its Final Report to the European Commission on 16 December 2024.

The Commission subsequently adopted the relevant CTP technical standards. These cover the data to be supplied to CTPs, data quality and related operational requirements.

The CTP framework is now moving from legislative implementation into operational rollout. ESMA has issued Q&As addressing the onboarding of data contributors and has reminded trading venues and APAs that they have legal obligations to contribute data from the relevant CTP go-live. ESMA expects contributors to engage with selected CTPs ahead of formal authorisation and to undertake connectivity and end-to-end testing.

23 November 2026

ESMA main consultation and supplementary consultation (closed 28 August 2024 and 15 September 2024, respectively)

AIMA summary of ESMA main consultation

AIMA summary of ESMA supplementary consultation

AIMA response to ESMA main consultation

[No AIMA response to ESMA supplementary consultation]

ESMA Final Report

European Commission Delegated Act specifying input and output data, synchronisation of business clocks and revenue distribution for shares and ETFs (adopted)

Annexes to Delegated Act specifying input and output data, synchronisation of business clocks and revenue distribution for shares and ETFs (adopted)

European Commission Delegated Act regarding standard forms, procedures for the authorisation of APAs, ARMs and CTPs and related notifications (adopted)

Annexes to Delegated Act regarding standard forms, procedures for the authorisation of APAs, ARMs and CTPs and related notifications (adopted)

ESMA consultation on amendment of input and output data of CTPs - specific data fields relevant to the derivatives CTP only (closes 3 July 2025)

MiFIR Review Article 22

RTS specifying the level of accuracy to which business clocks used for recording the date and time of reportable events are to be synchronised.

The business-clock requirements were developed as part of the CTP Level 2 package.

The European Commission adopted the relevant Delegated Act on 12 June 2025, with publication in the Official Journal on 3 November 2025.

Commission Delegated Regulation (EU) 2025/1155 specifies the input and output data for consolidated tapes, synchronisation of business clocks and revenue redistribution for shares and ETFs.

ESMA has issued Q&As clarifying, among other matters, the timestamp requirements for data transmitted to CTPs.

The provisions relating to business-clock synchronisation applied from 2 March 2026, with further CTP provisions applying from 23 November 2026.

MiFIR Review Article 28

RTS specifying the information to be provided by applicant CTPs to ESMA and the information to be included in the notifications as regards CTPs.

The MiFIR Review established the framework for the authorisation and supervision of CTPs. ESMA's December 2024 Final Report covered the relevant Level 2 requirements.

The Commission subsequently adopted the technical standards concerning standard forms and procedures for the authorisation of APAs, ARMs and CTPs.

Firms involved in CTP data contribution should monitor the relevant CTP authorisation and go-live timetable for each asset class rather than assuming a single EU-wide implementation date.

The CTP regime is being implemented separately by asset class. ESMA selected EuroCTP as the equities CTP in December 2025 and authorised it on 27 July 2026. EuroCTP was given a transition period until 30 September 2026 to complete operational and technical arrangements.

ESMA also selected Etrading Software as the OTC derivatives CTP in July 2026.

MiFIR Review Article 28 =

ITS specifying the standard forms, templates and procedures for the information to be provided by applicant CTPs for authorisation

23 November 2026

MiFIR Review Article 32 -

RTS specifying the weight assigned to each CTP revenue redistribution scheme crtierion, the method for calculating the amount of the revenue to be redistributed to data contributors, the criteria under which the CTP can suspend temporarily the participation of that data contributor in the revenue redistribution scheme and the conditions under which the CTP is to resume revenue redistribution and, where there was no breach of the CTP's requirements, provide that data contributor with the revenue retained plus interest.

The revenue redistribution framework was developed alongside the wider CTP Level 2 package.

ESMA submitted its Final Report on 16 December 2024 and the Commission subsequently adopted the relevant technical standards.

23 November 2026 for the relevant provisions. Implementation linked to CTP operational rollout.

MiFIR Review Article 3

*amended* RTS 1 and Technical Advice on the liquidity assessment for equity instruments and on equity transparency (specifying the details of pre-trade data to be made public for classes of financial instruments).

The Review amended the equity transparency framework, including requirements relating to pre-trade transparency information and the determination of the most relevant market in terms of liquidity.

ESMA consulted on the changes in its 2024 Level 2 consultation package and submitted its Final Report in December 2024.

The European Commission adopted the relevant Delegated Act on 18 June 2025, with publication in the Official Journal on 3 November 2025.

Firms should review equity instrument liquidity classifications, transparency calculations, pre-trade data requirements and the identification of the most relevant market in terms of liquidity.

Certain provisions applied from 2 March 2026, with further provisions applying from 23 November 2026.

ESMA has already implemented related changes to its transparency reporting systems. From April 2026, ESMA's reporting framework was updated to reflect the revised RTS 1 and RTS 2 calculations.

ESMA consultation (closed 15 September 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

European Commission Delegated Act (adopted)

Annexes to Delegated Act (adopted)

MiFID II Review Article 4

RTS specifying the criteria to be taken into account in establishing and assessing the effectiveness of investment firms’ order execution policies.

ESMA consulted on the proposed RTS in 2024 and submitted its Final Report to the European Commission on 10 April 2025.

The Commission has endorsed the RTS through Commission Delegated Regulation (EU) 2026/825, adopted on 14 April 2026 and published in the Official Journal on 23 July 2026. It entered into force on 12 August 2026.

The Regulation repeals the existing RTS 27 and RTS 28 delegated regulations and introduces detailed requirements concerning order execution policies and their ongoing assessment.

The new requirements include, among other things:

the factors and criteria firms must consider when selecting execution venues;
the use of reference data, including consolidated tape data where available;
treatment of automatic order-routing systems;
specific client instructions;
execution when dealing on own account;
monitoring of the effectiveness of the order execution policy;
quantitative thresholds for assessing execution quality;
annual assessment of the effectiveness of the policy; and
additional assessments following material changes or identified deficiencies.

Firms should now begin a detailed gap analysis against the final RTS rather than waiting until 2028. This should cover order execution policies, venue selection, execution-quality monitoring, reference data, automatic routing, OTC execution and governance/annual review processes.

12 February 2028. The 18-month period between entry into force and application is intended to give firms time to adjust their policies, procedures and IT infrastructure.

ESMA consultation (closed 16 October 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFID II Review Articles 10 - 11

RTS on position management controls, ITS 4 on the format of position reports by investment firms and market operators and Technical Advice on position reporting thresholds.

ESMA consulted on the changes in May 2024 and submitted its Final Report to the European Commission on 16 December 2024.

The Review extends position-management controls to trading venues trading derivatives on emission allowances and makes changes to position reporting, including the exclusion of spot emission allowances and enhanced reporting arrangements.

The original implementation timetable anticipated Commission adoption of the position-management RTS in Q4 2025 and ITS 4 in Q1 2026.

The technical implementation has since progressed. ESMA confirmed on 14 August 2026 that the new weekly commodity derivatives position-reporting framework would go live on 3 September 2026. Market participants must submit weekly position reports using the updated requirements, technical specifications and XML Schema v2.0.

Firms subject to position reporting should ensure that reporting arrangements, data mappings, validation and controls have been updated to the current technical specifications.

Q4 2025: Expected final EC RTS on position management controls for commodity derivatives

Q1 2026: Expected final EC ITS 4 on position reporting in commodity derivatives

ESMA consultation (closed 23 August 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFIR Review Article 4

RTS specifying the method, including the flagging of transactions, by which it collates, calculates and publishes the transaction data, to provide an accurate measurement of the total volume of trading per financial instrument and the percentages of trading that use the waiver under the single volume cap across the EU.

The MiFIR Review replaces the former double volume cap with a single 7% volume cap.

ESMA consulted on the relevant technical standards in 2024 and submitted its Final Report to the European Commission on 10 April 2025.

The Final Report covers:

the methodology for calculating the single volume cap;
transparency calculations;
the phasing out of certain daily reporting;
the revised SI notification regime; and
related circuit-breaker requirements.

ESMA consultation (closed 15 October 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFIR Review Article 7

RTS specifying waivers for bonds, structured finance products, emission allowances, derivatives and package orders.

The Review changes the waiver framework for pre-trade transparency and introduces specific provisions concerning derivatives and package orders.

ESMA consulted on the non-equity elements in 2024 and subsequently launched a further consultation on derivatives transparency and package orders in April 2025.

ESMA published its Final Report on derivatives transparency, package orders and CTP input/output data in December 2025. The Final Report covers pre- and post-trade transparency for ETDs and OTC derivatives, the deferral regime and package orders.

Firms trading derivatives should assess the proposed impact on pre- and post-trade transparency, waiver eligibility, package-order treatment and deferrals.

ESMA Final Report completed; Commission Level 2 process ongoing. ESMA's final proposals envisage application of the revised derivatives transparency framework from 1 March 2027, subject to completion of the Commission adoption process.

ESMA consultation (closed 28 August 2024 - for bonds, SFPs and emission allowances)

[No AIMA response to August 2024 consultation]

ESMA consultation - derivatives and package orders (closes 3 July 2025)

MiFIR Review Article 13

RTS specifying the minimum quote size of systematic internalisers.

ESMA consulted on the revised SI requirements as part of its 2024 consultation package and submitted its Final Report on 10 April 2025.

The Final Report formed part of ESMA's wider work on the revised SI notification regime, single volume cap and circuit breakers.

ESMA Final Report completed; Commission Level 2 process to be monitored.

ESMA consultation (closed 15 October 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFIR Review Article 14

ITS specifying the content and format of the notification for systematic internalisers.

The MiFIR Review moves away from the previous quantitative SI assessment framework and introduces a revised notification approach.

ESMA consulted on the revised notification requirements in 2024 and submitted its Final Report on 10 April 2025.

MiFIR Review Article 25

*amended* RTS 24 on the reporting of transactions to competent authorities (specifying the details and formats of the order data that trading venue operators are required to maintain and keep at the disposal of the national competent authorities for atleast five years).

ESMA consulted on the review of RTS 24 alongside RTS 22 in late 2024.

ESMA published its Final Report on RTS 22 and RTS 24 on 23 June 2025.

The revised standards address the details and format of order data to be maintained by trading venue operators and available to competent authorities.

ESMA Final Report completed; Commission Level 2 process to be monitored.

ESMA consultation (closes 3 January 2025)

AIMA summary of ESMA consultation

MiFIR Review Article 46

European Commission assessment of the possibility of extending the transaction reporting requirements under Article 26 MiFIR to AIFMs as defined in Article 4(1), point (b), of Directive 2011/61/EU, and management companies, as defined in Article 2(1), point (b), of Directive 2009/65/EC, which provide investment services and activities and which execute transactions in financial instruments.

AIFMs and UCITS management companies should monitor this work separately from the RTS 22 implementation.

29 March 2025 - delayed. Commission assessment – monitor for further development.

MiFID II Review Article 7

*recast* RTS 7a on organisational requirements of trading venues, adding new provisions on circuit breakers and with targeted amendments to adapt to the DORA framework.

ESMA consulted on the revised requirements in 2024 and submitted its Final Report to the European Commission on 10 April 2025.

The Final Report covers circuit breakers alongside the revised SI notification regime and single-volume-cap methodology.

10 July 2025: Deadline for European Commission to decide whether to endorse ESMA's proposed amendments

ESMA Final Report completed; Commission Level 2 process to be monitored.

ESMA consultation (closed 15 October 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFIR Review Article 10

RTS specifying deferred publication in respect of derivatives.

The Review establishes a revised framework for post-trade transparency and deferrals for derivatives.

ESMA consulted on the revised derivatives transparency framework in April 2025 and published its Final Report in December 2025.

The Final Report addresses:

pre- and post-trade transparency;
liquidity determination;
deferrals;
package orders; and
the interaction between the derivatives transparency framework and the OTC derivatives CTP.

Firms should assess the proposed changes to deferral periods, transparency eligibility and the interaction with the new OTC derivative reference-data regime.

The revised derivatives transparency regime is expected to apply from 1 March 2027, subject to completion of the Level 2 process. ESMA Final Report completed; Commission adoption pending.

ESMA consultation (closes 3 July 2025)

MiFIR Review Article 25

RTS specifying financial instruments reference data.

The revised RTS updates the reference-data requirements used for transparency and supervisory purposes. It also needs to be considered alongside the separate Commission Delegated Regulation on OTC derivatives identifying reference data.

Q1 2025: Expected EC adoption of RTS 23

ESMA Final Report completed; implementation of the revised reference-data framework is progressing.

The OTC derivative identifying-reference-data element is already operational from 1 September 2026 under Commission Delegated Regulation (EU) 2025/1003.

ESMA consultation (closed 28 August 2024)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFIR Review Article 26

*amended* RTS 22 on transaction data reporting (incl. the conditions for linking specific transactions and the means of identifying of aggregated orders resulting in the execution of a transaction; and the date by which transactions are to be reported).

ESMA consulted on RTS 22 in late 2024. The consultation closed on 3 January 2025.

ESMA published its Final Report on 23 June 2025, covering both RTS 22 and RTS 24.

The revised RTS is intended to improve the quality and usefulness of transaction data while reducing unnecessary reporting complexity.

Firms should undertake a systems impact assessment covering transaction-reporting fields, data sourcing, instrument identifiers, order identifiers, aggregation/linking requirements, reporting timing and reconciliation.

Q4 2025: Expected EC adoption of RTS 22 on Transaction Data Reporting

ESMA Final Report completed; Commission Level 2 adoption/application to be monitored.

ESMA consultation (closed 3 January 2025)

AIMA summary of ESMA consultation

[No AIMA response]

ESMA Final Report

MiFIR Review Article 33

RTS specifying the content, timing, format and terminology of the reporting obligation for CTPs to publish performance statistics and incident reports relating to data quality and data systems.

The requirements form part of the wider CTP Level 2 package.

ESMA submitted its Final Report on 16 December 2024, with the Commission subsequently adopting the relevant technical standards.

Adopted – implementation linked to CTP operational rollout.

See above rows on MiFIR Review Articles 22, 28 and 32

MiFIR Review Article 1

RTS specifying the monetary, foreign exchange and financial stability policy operations and the types of transactions to which the exemption from transparency requirements will not apply with regard to members of the European System of Central Banks which are not members of the Eurosystem.

ESMA consulted on the measure as part of the April 2025 consultation package, with the consultation closing on 3 July 2025.

29 March 2026

Q4 2025: ESMA publication of Final Report and submission of RTS to the European Commission for adoption

ESMA consultation (closed 3 July 2025)

[No AIMA response]

Longer-term MiFIR Review reporting and review obligations

The MiFIR Review also contains a number of longer-term reports and assessments. These are not immediate implementation measures but are relevant to the continuing development of the MiFIR framework.

MiFIR Review Article 46 – consolidated tape assessment

ESMA is required to report to the European Commission on the market demand for the consolidated tape for shares and ETFs, its impact on the functioning, attractiveness and international competitiveness of EU markets, whether the tape is meeting its objectives, and whether additional features should be introduced.

Deadline: 30 June 2026.

This should be treated as a continuing Review deliverable rather than a firm-level implementation deadline.

MiFIR Review Article 4 – review of the single volume cap

ESMA is required to assess the single-volume-cap threshold, taking into account financial stability, international practices, the competitiveness of EU firms, market impact and the efficiency of price formation.

Deadline: 29 September 2027, and annually thereafter.

This is separate from the Level 2 RTS establishing the methodology for calculating and publishing the single volume cap.

MiFIR Review Article 52 – review of the single volume cap

The Commission is required to report to the European Parliament and Council on the appropriateness of the single volume cap, including whether it should be removed or extended to other trading systems or execution venues that derive prices from a reference price.

Deadline: 29 March 2028.

MiFIR Review Article 25 – integration of transaction reporting

ESMA is required to report to the European Commission on the feasibility of greater integration of transaction reporting and the streamlining of data flows.

Deadline: 29 March 2028.

This longer-term review should be distinguished from the immediate RTS 22 implementation.

MiFIR Review Article 52 – consolidated tape review

The Commission is required, after consulting ESMA, to report on the operation of the consolidated tape framework, including:

the asset classes covered;
timeliness and quality of data supplied to CTPs;
timeliness and quality of core market and regulatory data;
use of the consolidated tape by market participants;
the effect of the tape on information asymmetries;
data-transmission protocols;
the revenue-redistribution mechanism; and
the effect of the framework on investment in SMEs.

Timing: Three years after the first CTP authorisation.

The CTP framework is now moving into operational implementation. ESMA authorised EuroCTP as the equities CTP on 27 July 2026, with a transition period until 30 September 2026.

MiFIR Review Article 27 – APA/ARM authorisation procedures

Measure: ITS specifying the standard forms, templates and procedures for information to be provided by applicant APAs and ARMs for authorisation.

Deadline: No specific deadline stated in the MiFIR Review text.

This forms part of the broader data-reporting-services-provider and CTP authorisation framework.

Timeline

Trading in financial instruments under the single volume cap to be monitored:	29 September 2025
Publication of the first results for the “single” volume cap mechanism	9 October 2025
MiFID II Review Transposition Date:⁷	28 September 2025
Expected publication of (i) RTS 2 on Non-Equity Transparency, excl. derivatives; (ii) RTS on Reasonable Commercial Basis; (iii) Technical Standards on CTPs and DRSPs; (iv) RTS 1 on Equity Transparency; and (v) Technical Standards and Advice for Commodity Derivatives in the Official Journal of the EU:⁶	15 November 2025
Deadline for the European Commission to decide whether to endorse ESMA's proposed Level 2 amendments to (i) RTS on Order Execution Policies; (ii) RTS on the single volume cap and transparency calculations; (iii) RTS on trading venues' organisational requirements and circuit breakers; and (iv) ITS on SI notifications:⁵	10 July 2025
Deadline for the European Commission and ESMA to assess an extension of Article 26 transaction reporting requirements:⁴	29 March 2025 (delayed)
MiFIR Review Implementation Date:³	28 March 2024
MiFIR Review and MiFID II Review Effective Date:²	28 March 2024
MiFIR Review and MiFID II Review OJEU Publication Date:¹	8 March 2024

¹Following the provisional political agreement that was reached on 29 June 2023, technical discussions on the MiFIR Review and MiFID II Review texts continued and, in October 2023, agreements were reached. The final texts of the Regulation amending MiFIR and the Directive amending MiFID II were published in the Official Journal of the EU on 8 March 2024.

² The Regulation amending MiFIR and the Directive amending MiFID II took effect 20 days after publication in the Official Journal of the EU.

³The Regulation amending MiFIR is binding in its entirety and directly applicable in all Member States.

⁴The MiFIR Review mandates the European Commission, with ESMA, to assess whether or not to extend transaction reporting requirements under Article 26 MiFIR to AIFMs and UCITS ManCos with MiFID 'top-up' permissions by 29 March 2025. The European Commission is empowered to adopt delegated acts to effect this extension.

⁵See 'Pending Implementation Measures' table below for further details. Once the Technical Standards are adopted by the European Commission, they will be submitted to the European Parliament and the Council of the EU for a period of non-objection (usually up to 3 months) before publication in the Official Journal of the EU. The technical standards will enter force 20 days after publication in the Offical Journal.

⁶See 'Pending Implementation Measures' table below for further details. Once the Technical Standards are adopted by the European Commission, they will be submitted to the European Parliament and the Council of the EU for a period of non-objection (usually up to 3 months) before publication in the Official Journal of the EU. The technical standards will enter force 20 days after publication in the Offical Journal.

⁷Member States will have 18 months after the Directive amending MiFID II takes effect to bring into force the laws, regulations and administrative provisions necessary to comply with the Directive.

Pending Implementation Measures

The amendments introduced to the Level 1 texts include a number of Level 2 measures that are to be developed during the implementation period. “Implementing Measures” include (i) regulatory technical standards, (ii) implementing technical standards (which may be developed by ESMA to be adopted by the European Commission, including by delegated acts in accordance with the Treaty on the Functioning of the European Union, and (iii) guidelines developed by ESMA, in each case where expressly mandated in the Level 1 texts. The date of entry into application of the Level 2 measures is subject to their adoption by the European Commission and approval by the European Parliament and the Council of the EU. The technical standards will be published in the Official Journal of the EU and be binding in their entirety and directly applicable in all Member States. Where needed, they will also provide for an implementation period.

A list of ESMA and the European Commission's published Level 2 consultations are provided below.

ESMA Consultation Packages 1 and 2 [closed]

(All ESMA Final Reports published. Adoption by European Commission/ OFJEU publication pending)

*New* Regulatory Technical Standards and Implementing Technical Standard relating to consolidated tape providers (CTPs) and other data reporting service providers - adopted in June 2025, OFJEU publication on 3 November 2025.
*Amended* Regulatory Technical Standard 2 on Non-Equity Transparency - adopted in June 2025, OFJEU publication on 3 November 2025.
*New* Regulatory Technical Standards on Reasonable Commercial Basis - adopted in June 2025, OFJEU publication on 3 November 2025.
*Amended* Technical Standards and Advice relating to commodity derivatives - RTS on position management controls expected to be adopted in Q4 2025; ITS 4 on position reporting in commodity derivatives expected to be adopted in Q1 2026.
*Amended* Regulatory Technical Standard 23 on Financial Instruments Reference Data - expected to be adopted in Q1 2025.

ESMA Consultation Package 3 [closed]

(All ESMA Final Reports published. Adoption by European Commission/ OFJEU publication pending)

*Amended* Regulatory Technical Standard and Technical Advice on the liquidity assessment for equity instruments and on equity transparency - adopted in June 2025, OFJEU publication on 3 November 2025..
*New* Implementing Technical Standard (ITS) on the content and format of the systematic internaliser (SI) notification - ESMA Final Report published on 10 April 2025. Adoption in Q2 2025. OFJEU publication expected by November 2025.
*Amended* RTS 3 on the volume cap - ESMA Final Report published on 10 April 2025. ESMA has submitted the amendment to RTS 3 for adoption. In case the RTS 3 revision is not yet in place at that moment, the VCM switch will occur in Q4 2025. First publication of the calculation results - 9 October 2025 at 18:00h
*Recast* RTS 7a on organisational requirements of trading venues, adding new provisions on circuit breakers and with targeted amendments to adapt to the DORA framework - ESMA Final Report published on 10 April 2025.
*New* RTS on input and output data for shares and ETFs consolidated tape provider (CTP) - adopted in June 2025, OFJEU publication on 3 November 2025.
*Amended* RTS 2 on flags for post-trade transparency reports for non-equity instruments - adopted in June 2025, OFJEU publication expected by September 2025.
*New* RTS on the criteria for establishing and assessing the effectiveness of investment firms’ order execution policies - ESMA Final Report published on 10 April 2025. Expected to be adopted in Q2 2026.

ESMA Consultation Package 4 [closed]

(All ESMA Final Reports published. Adoption by European Commission pending)

*Amended* RTS 22 on transaction data reporting under Article 26 (closed 17 January 2025). ESMA Final Report published on 23 June 2025. Expected to be adopted in Q4 2025.
*Amended* RTS 24 on order book data to be maintained under Article 25 of MiFIR (closed 17 January 2025). ESMA Final Report published on 23 June 2025. Expected to be adopted in Q4 2025.

ESMA Consultation Package 5 [closed]

(Published in OFJEU on 13 July 2026. All take effect 1 March 2027)

*Amended* RTS on the transaprency requirements for derivatives and the ESCB exemption (closed 3 July 2025). ESMA Final Report published in Q4 2025. OFJEU publication.
*Amended* RTS on the input and output data of CTPs - specific data fields relevant to the derivatives CTP (closed 3 July 2025). ESMA Final Report published in Q4 2025. OFJEU publication.
*Amended* RTS on Package Orders - additional asset class-specific critieria, not mandated under the EU MiFIR Review (closed 3 July 2025). ESMA Final Report published in Q4 2025. OFJEU publication.