The European Commission’s proposal on MiFIR establishes the blueprint for a consolidated tape (CT) for Europe’s capital markets. It also significantly alters the competitive market structure brought about by MiFID II by introducing greater transparency requirements. Finally, it addresses important issues around market data costs.

EFAMA fully supports most aspects of the CT proposal, including:
- As close to real-time delivery of data as possible (meaning millisecond range for equities, and minute speed for bonds)
- Mandatory contribution by trading venues, APAs and SIs
- Voluntary consumption of the CT
- A single CT provider model
- Consolidated tapes for multiple asset classes

At the same time, we voice important reservations about the proposed revenue model for the CT providers. Also, while data quality issues can be addressed through the proposed data expert group, there is a need for an explicitly defined market surveillance body to enforce data standards and deter/reduce the provision of poor quality data.

On market structure reform, the proposed transparency requirements are far-reaching, not always supported by evidence and will result in less diversity, choice and competition in Europe’s capital markets.

On market data costs, we are fully aligned with the EC proposal, though we would like the proposal to go further and reflect ESMA’s recent recommendations on this topic.

Finally, a common theme underpinning our position is a concern that the proposed reforms as they stand today would reduce Europe’s attractiveness as a destination for global investors, that EU firms would be placed at a disadvantage compared to their non-EU peers, and that opportunities around increasing retail investor confidence and facilitating digital transformation would not be fully seized.