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Publishing to APAs: what’s the MiFID II solution?

Tricia San Cristobal
Tricia San Cristobal
Global Proposition Manager, Enterprise Platform, Refinitiv

MiFID II requirements on publishing pre- and post-trade data to one or more APA (Approved Publication Arrangement) leaves financial institutions needing to find the path of least resistance to compliance.

Europe’s MiFID II directive, which comes into force on 3 January, is bringing an entirely new set of market data publication requirements to investment firms and trading venues.

Publishing this data to one or more APA requires setting up connectivity to an APA, as well as conforming to their messaging specifications.

And as these transparency requirements move into the over-the-counter (OTC) space, there will be a huge increase in instrument coverage, both in number and asset type.

Organizations will need to find the simplest way to ensure the requirements are being met, while still running their business processes as seamlessly as possible.


Many businesses will consider sorting out their own APA connectivity in-house, along with the scoping, managing and testing this entails.

This do-it-yourself option requires making sure you have the data in the correct format demanded by each APA. If you plan to connect to more than one APA, multiply the above.

This can be time-consuming for in-house resources. And given everything else that needs to be done regarding MiFID II, why add more to the overheads and workload if you don’t have to?

We are committed to bringing together as many of the new data sources as needed, whether this is new systematic internaliser (SI) quotes, OTC quotes and trade reports from APAs, new trading venues, or just new transparency data from existing markets.

Outsourcing route

Another option is outsourcing, where organizations can give the task of APA connectivity to someone else to capture quote and trade data, and publish it to the chosen APA.

By outsourcing, you can capture pre- and post-trade publication services for whatever you need — bonds, structured finance products, derivatives and emission allowances.

And publication can be simplified by including deferral and waiver rules into the platform.

Together, this information allows investors to see the execution benefit that equals or betters that available from public venues.

If you prefer the outsourcing route, Refinitiv provides a single format for you to use. We then convert the data you give us into the correct format for whichever APA you’re publishing with, before sending it to them for you.

The result? You can divert development, systems and network resources to core business or other projects that bring a competitive advantage. You can also save set up and testing time.

APAs we’re currently connecting to are Tradeweb, TRADEcho and Bats, and we’ll be adding more, subject to demand, in 2018.

Bolt-on connectivity

For our Enterprise Platform clients who have pre-trade information on their enterprise platform, we have developed a OMM/FIX adaptor that our clients can download off GitHub.

This allows them to transform OMM to FIX easily, and take advantage of the connectivity we’re offering.

If you’re already using a Refinitiv data service or our enterprise platform (TREP), adding our APA Connectivity is simple. And once testing is complete, away you go.

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