To achieve MiFID II’s aim of greater transparency, having a proper golden source of instrument data is key for every market participant. Fortunately, under the new rules, ESMA is required to publish a list of all financial instruments traded on all trading venues and systematic internalisers, enriched with useful, related information such as MiFIR transparency and liquidity thresholds. ESMA is always keen to point out that this should not be seen as the golden source. The trouble is, almost everyone else in the market is left wondering, if this isn’t it, then what is?
But whether it’s truly golden or merely gilded it’s somewhat irrelevant if ESMA doesn’t move forward soon. Since the announcement of centralised data projects for MiFIR and EMIR in April 2015 ESMA has made no further public statements. This is rather worrying, given that nearly every MiFID II requirement, be it around transaction and trade reporting, record-keeping, or something else, somehow links back to instrument data.