Equiduct is already considered to be both pre- and post-trade transparent under MiFID, and the requirements for transparency in respect of Regulated Markets and MTFs are unchanged in MiFID II.
RTS 1 stipulates the size of orders to be considered as Large In Scale (LIS) by using data collected by all of the NCAs from their trading venues to calculate Average Daily Turnover (ADT). The ADT bands have been prescribed in MiFID II. Should Equiduct in future offer LIS trading facilities, we will include the relevant order size thresholds in our published instrument list.
The ADT calculation will also be used to determine the SMS bands under MiFID II. Equiduct already publishes the SMS values per instrument, along with our own RMS values, in our instrument list. Equiduct will continue to publish this data using the new methodology under MiFID II.
There will be some changes that Equiduct will need to develop in order to meet the requirements of MiFID II. These include implementing a minimum iceberg order size (€10,000) and providing new post trade market data flags to identify transactions such as Agency Cross, Algorithmic and (if applicable) LIS transactions.Equiduct will be developing the required reports for submitting reference data to our NCA (BaFin) for the purposes of transparency calculations.