E.U. – ESMA MiFID Bond Transparency

On 11 September, ESMA revised transitional transparency, FAQs for bonds.

  • Transitional transparency of bonds, update calculation of two other asset classes.
  • Follows EC March 2017 transparency rules for bonds in official journal.
  • Used to waive the obligation to make public pre-trade information for larger size.
  • Applied for market operators, and to investment firms operating a trading venue.

Transitional Calculation

  • MiFID II requires EU State NCAs, to publish information on liquidity classifications.
  • On sizes large in scale (LIS) vs. normal market, size specific to instrument (SSTI).
  • Publish six months prior to date of application of MiFIR, schedule on 3 January 2018.
  • All EEA NCAs, except for Poland, have delegated to ESMA, the compilation of TTC.
  • ESMA compiled transitional calculation using data provided by EEA trading venues.
  • Results of calculations by Poland were included in files published on ESMA website.

Revision of July 2017 Data

  • On 3 July 2017, ESMA published TTC on all non-equities except bonds.
  • September 2017 data is revising ESMA July 2017 transparency calculation for non-equity,
  • Publication delay as ESMA detected data quality problem, requested resubmission.
  • Final calculations incorporated data on OTC market information provided by TRAX.
  • After TTC publication in July 2017, some venues notified ESMA of problems in data.
  • The problem affected the calculations for credit derivatives and equity derivatives.
  • Thus, ESMA has corrected and recalculated TTC, for both asset classes accordingly.
  • ESMA said performed the calculations with great care, and to the best of its ability.
  • However, given complexity of calculations, further changes can’t fully be ruled out.
  • ESMA expected to continuously supplement and update data provided as necessary.
  • Any future update will be published on ESMA site with information in news section.

Data by Asset Class

Legal Entity Identifiers (LEIs)

  • ESMA noted LEIs were not provided for some reference entities for single name CDS,
    and issuers of underlying bond on rate derivativeS, but will be mandatory January 2018.

Sweden – SFI Commodity Position Limit

On 5 September, SFI proposed rules on commodity position limits under MiFID.

  • Proposed new regulations which establish position limits on commodity derivatives.

MiFID Limits

  • Regulations put into effect the legislative changes brought about by MiFID II/MiFIR.
  • MiFID II require competent authorities to establish position limits for commodities.
  • Restrict net position that natural or legal person may hold in commodity derivative.
  • If traded in a trading venue in Sweden, and economically equivalent OTC contracts.


  • Consultation period on the proposed regulations comes to an end on 22 September 2017.
  • Proposed to come into effect alongside the legislative amendments, on 3 January 2018.