EBF adviser: Pauline Guérin

Publication date: 12 September 2019

General Comments:

EBF share the view that the costs for market data have increased since the entry into application of MIFID 2.

Despite the directive stressing that the costs of market data should be provided on a reasonable commercial basis, explicitly specified as being based on cost with a reasonable margin, the new requirement hasn’t reached its objective. Overall market data costs and complexity have continued to increase whereas market data transparency and data quality have decreased. The main cost driver for market data users is not so much increase in already existing fees but the introduction of new fees related to multiple display-terminal, non-display applications, reporting and distribution licences, systematic internalisers market data fee, connectivity fees etc. – in combination with unclear and complex market data policies and definitions and unreasonable audit procedures. Additionally, regulatory requirements contribute to the increasing cost of market data. E.g. the Market Abuse Regulation require access to realtime data to ensure proper surveillance.

Thus, the EBF members call for further action from ESMA.