# Can a Single Best Execution Policy Satisfy Both the Fca and an Eu National Competent Authority? ▴ Question

**Published:** 2025-08-09
**Categories:** Question

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![A precision institutional interface features a vertical display, control knobs, and a sharp element. This RFQ Protocol system ensures High-Fidelity Execution and optimal Price Discovery, facilitating Liquidity Aggregation](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-execution-platform-interface.jpg)

![Four sleek, rounded, modular components stack, symbolizing a multi-layered institutional digital asset derivatives trading system. Each unit represents a critical Prime RFQ layer, facilitating high-fidelity execution, aggregated inquiry, and sophisticated market microstructure for optimal price discovery via RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/07/modular-institutional-crypto-derivatives-trading-system-components.jpg)

## Concept

![Precision-engineered modular components, with teal accents, align at a central interface. This visually embodies an RFQ protocol for institutional digital asset derivatives, facilitating principal liquidity aggregation and high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/precision-engineered-institutional-digital-asset-derivatives-rfq-execution-interface-for-atomic-settlement.jpg)

## The Common Ancestry of a Divided Obligation

For any financial institution operating across the UK and European Union, the principle of [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) represents a foundational pillar of market conduct. It is the tangible commitment to client interests, an obligation to secure the most favorable terms available when carrying out their orders. The question of whether a single, unified policy can satisfy the regulatory demands of both the Financial Conduct Authority ([FCA](https://prime.greeks.live/area/fca/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)) and a European National Competent Authority (NCA) is a direct consequence of Brexit.

The divergence of two regulatory systems from a common origin, [MiFID II](https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (Markets in Financial Instruments Directive II), creates a complex operational challenge. This is not a theoretical exercise; it is a critical examination of a firm’s internal systems, its governance structure, and its capacity to navigate a fragmented legal landscape while upholding a singular, high standard of client care.

The genesis of the current framework lies in the comprehensive standards set by MiFID II, a legislative suite designed to harmonize financial markets across the European Union, enhancing transparency, investor protection, and competition. Both the UK and the EU regimes are branches of this same tree, and consequently, they share a significant amount of DNA. The core obligation remains identical in spirit and in much of its text ▴ firms must take all sufficient steps to obtain the best possible result for their clients. This overarching duty is assessed against a consistent set of [execution factors](https://prime.greeks.live/question/how-does-mifid-ii-define-the-execution-factors-for-determining-best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), including price, costs, speed, likelihood of execution and settlement, size, and the nature of the order.

The fundamental expectation of identifying and managing conflicts of interest, and of establishing robust governance and monitoring processes, persists on both sides of the English Channel. This shared heritage provides the foundation upon which any viable compliance structure must be built.

> A unified best execution policy is operationally desirable but practically complex, requiring a flexible, data-driven framework that accommodates regulatory divergence rather than a single, rigid document.

![A precise stack of multi-layered circular components visually representing a sophisticated Principal Digital Asset RFQ framework. Each distinct layer signifies a critical component within market microstructure for high-fidelity execution of institutional digital asset derivatives, embodying liquidity aggregation across dark pools, enabling private quotation and atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/principal-digital-asset-rfq-protocol-layers-for-high-fidelity-execution.jpg)

## Divergence beyond the Principle

The complexities arise not from the core principle itself, but from the specific, technical, and procedural requirements that each jurisdiction has established to supervise and enforce it. Post-Brexit, the UK has embarked on a path of tailoring its financial rulebook to the perceived needs of its domestic market. This has led to material changes in how firms are expected to demonstrate compliance. The most prominent area of divergence is in the realm of transparency and reporting.

The UK’s decision to abolish the obligations under Regulatory Technical Standards (RTS) 27 and 28, which mandated detailed public reports on execution quality from venues and firms, marks a significant departure from the EU’s approach. While the EU has also acknowledged the limited utility of these reports and has moved to deprioritize their enforcement, its legislative direction points towards reform and simplification rather than complete removal.

This single change creates a fundamental divide. For a firm with operations in both London and an EU capital, the processes for data collection, analysis, and public disclosure are now fundamentally different. What is a decommissioned requirement in the UK remains a live, albeit evolving, obligation in the EU. This necessitates a dual-track approach to compliance monitoring and reporting.

Furthermore, subtle but important shifts in rules surrounding research payments and pre-trade transparency for certain types of venues add further layers of complexity. A policy document, therefore, must do more than just state a commitment to a principle. It must serve as an operational map for navigating two distinct sets of procedural expectations, ensuring that the firm’s actions are compliant, demonstrable, and defensible in each jurisdiction independently. The challenge is to create a coherent internal system that can manage this duality without introducing unnecessary friction or compromising the integrity of the overarching client-first obligation.

![A disaggregated institutional-grade digital asset derivatives module, off-white and grey, features a precise brass-ringed aperture. It visualizes an RFQ protocol interface, enabling high-fidelity execution, managing counterparty risk, and optimizing price discovery within market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-protocol-modular-execution-intelligence-system.jpg)

![A precision-engineered, multi-layered system architecture for institutional digital asset derivatives. Its modular components signify robust RFQ protocol integration, facilitating efficient price discovery and high-fidelity execution for complex multi-leg spreads, minimizing slippage and adverse selection in market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-institutional-digital-asset-derivatives-rfq-execution-platform.jpg)

## Strategy

![Precision-engineered modular components, with transparent elements and metallic conduits, depict a robust RFQ Protocol engine. This architecture facilitates high-fidelity execution for institutional digital asset derivatives, enabling efficient liquidity aggregation and atomic settlement within market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-optimizing-high-fidelity-execution-and-liquidity-aggregation.jpg)

## Harmonizing the Core Principles

The strategic starting point for any firm addressing the dual-regime challenge is to codify the extensive common ground. A successful approach builds upon the shared foundation of MiFID II, creating a central policy document that articulates the firm’s universal commitment to the principles of best execution. This core policy acts as the spine of the governance framework, establishing the high-level standards and methodologies that apply across all operations, regardless of location.

It defines the firm’s interpretation of “all sufficient steps” and outlines the qualitative and quantitative factors that guide execution decisions. By focusing on the enduring principles, a firm can foster a consistent culture of client-centricity and operational excellence.

This foundational document would detail the hierarchy and application of the primary execution factors. While the list of factors is identical between the UK and EU, a firm’s strategy must define how these are weighted and considered in different scenarios. For example, for a highly liquid equity order for a retail client, ‘price’ and ‘costs’ would be paramount. For a large, illiquid block trade for an institutional client, ‘likelihood of execution’ and ‘market impact’ might take precedence.

The core policy should articulate this logic clearly. It provides a consistent methodology for [venue selection](https://prime.greeks.live/question/how-does-an-rfq-platform-differentiate-between-on-venue-and-off-venue-reporting-obligations/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), outlining the criteria used to evaluate and approve [execution venues](https://prime.greeks.live/question/how-does-a-best-execution-committee-quantify-and-compare-execution-quality-across-different-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), and it establishes the mandate for a regular, systematic review of their performance. This creates a stable, auditable baseline that satisfies the fundamental expectations of both the FCA and EU NCAs.

![Abstract geometric design illustrating a central RFQ aggregation hub for institutional digital asset derivatives. Radiating lines symbolize high-fidelity execution via smart order routing across dark pools](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-high-fidelity-execution-architecture.jpg)

## Comparative Analysis of Execution Factors

The table below illustrates the foundational execution factors that remain consistent across both the UK’s and the EU’s regulatory frameworks. A strategic policy will leverage this consistency as the basis for a unified approach to trade execution logic, ensuring that the decision-making process for routing orders is grounded in a common set of client-centric criteria, irrespective of the trade’s booking location.

| Execution Factor | FCA (UK MiFID) Interpretation | EU NCA (MiFID II) Interpretation | Strategic Implication for a Unified Policy |
| --- | --- | --- | --- |
| Price | The primary consideration for achieving the best possible result, especially for retail clients. It refers to the monetary price of the financial instrument. | Remains the critical component of the overall consideration for the client. The focus on net price, after costs, is central to the obligation. | The core policy must enshrine price as a dominant factor, with clear methodologies for its measurement (e.g. arrival price, VWAP) across all asset classes. |
| Costs | All expenses incurred by the client that are directly related to the execution of the order, including execution venue fees, clearing and settlement fees, and any other fees paid to third parties. | Explicit and implicit costs are to be considered. This includes all commissions and fees that detract from the final value received by the client. | A unified Total Cost Analysis (TCA) framework is essential. The policy must define how all associated costs are captured, analyzed, and minimized. |
| Speed | The timeliness of execution. Its importance varies depending on the client’s objectives and the volatility of the market. | A key factor, particularly for clients or strategies that prioritize rapid execution to capture fleeting opportunities or minimize exposure. | The policy should define latency benchmarks and measurement standards, linking execution speed to specific order types and client instructions. |
| Likelihood of Execution and Settlement | A critical factor for illiquid instruments or large orders where the certainty of completion is a primary client objective. It includes counterparty and settlement risk. | The probability that the trade will be successfully executed and settled. This is of high importance in volatile or less liquid market conditions. | Venue and counterparty risk assessment protocols must be standardized. The policy needs to detail due diligence processes for all execution partners. |
| Size and Nature of the Order | The characteristics of the order itself, which can influence the choice of execution method and venue (e.g. a large block order may require an RFQ platform). | The size and type of order dictate the appropriate execution strategy, influencing whether a lit market, dark pool, or other venue is most suitable. | The policy must link order characteristics to pre-defined execution strategies and approved venue lists, ensuring a systematic approach to handling different trade types. |
| Any Other Relevant Consideration | A catch-all category that allows firms to use their judgment to include any other factor relevant to achieving the best outcome for the client. | Provides flexibility for the firm to account for any other pertinent elements that could affect the quality of the execution on behalf of the client. | The policy should provide a framework for identifying and documenting these considerations, ensuring that any deviation from standard procedure is justified and auditable. |

![A sophisticated teal and black device with gold accents symbolizes a Principal's operational framework for institutional digital asset derivatives. It represents a high-fidelity execution engine, integrating RFQ protocols for atomic settlement](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-core-engine-for-best-execution.jpg)

## Architecting for Divergence

While a core policy establishes consistency, the strategy must explicitly address the points of [regulatory divergence](https://prime.greeks.live/area/regulatory-divergence/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This is best achieved through a modular approach, creating [jurisdiction-specific annexes](https://prime.greeks.live/question/how-does-the-2002-isda-framework-influence-the-negotiation-of-credit-support-annexes/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) or addendums to the core policy. These annexes are not standalone documents; they are integral components of the overall framework that detail how the firm complies with the unique requirements of the FCA and the relevant EU NCA. This structure allows the firm to maintain a cohesive global standard while providing the granular detail necessary for local compliance and regulatory inspection.

The most significant divergence to be addressed is in reporting and transparency. The UK annex would formally state the firm’s acknowledgment of the removal of [RTS 27](https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and 28 reporting obligations. Conversely, the EU annex must detail the firm’s methodology for complying with the continuing, albeit evolving, [RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) requirements and its approach to monitoring ESMA’s stance on RTS 27. This includes defining the data sources, aggregation methods, and publication schedule for the top-five venue reports required in the EU.

Similarly, any differences in rules regarding venue selection (such as the UK’s removal of the double [volume cap](https://prime.greeks.live/area/volume-cap/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) on dark pool trading) must be detailed in the respective annexes, explaining how the firm’s venue selection logic adapts to the different regulatory environments. This modular strategy ensures clarity, prevents confusion, and demonstrates to regulators that the firm has a sophisticated and deliberate approach to managing its cross-jurisdictional obligations.

> A modular policy, combining a consistent core with jurisdiction-specific annexes, is the most effective strategy for managing the operational realities of divergent regulatory regimes.

![A sleek, modular metallic component, split beige and teal, features a central glossy black sphere. Precision details evoke an institutional grade Prime RFQ intelligence layer module](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-core-precision-platform-system.jpg)

## Mapping the Procedural Divide

The following table outlines the key areas of divergence in the procedural and reporting requirements between the UK and EU regimes. A robust strategy must translate these differences into distinct operational workflows, managed through the annex structure of the [best execution policy](https://prime.greeks.live/area/best-execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This ensures that the demonstration of compliance is tailored to the specific expectations of each regulator.

| Regulatory Area | FCA (UK) Position | ESMA/EU Position | Strategic Response for a Dual-Compliance Framework |
| --- | --- | --- | --- |
| RTS 27 Reporting (Venue Quality) | Obligation fully removed for UK execution venues as of December 2021. No requirement to produce or publish these quarterly reports. | Enforcement has been deprioritized by NCAs following ESMA guidance. The long-term direction is towards significant revision or removal, but the legal requirement has not yet been fully extinguished across all member states. | The UK annex will confirm the removal of this obligation. The EU annex will document the firm’s policy of monitoring ESMA guidance and adhering to any remaining or revised national requirements, while noting the deprioritization of enforcement. |
| RTS 28 Reporting (Top 5 Venues) | Obligation fully removed for UK firms as of December 2021. No requirement to publish this annual report. | Requirement remains in place, though it is under review. Firms must continue to produce and publish an annual report detailing the top five execution venues used for each class of financial instrument. | A bifurcated operational process is required. The UK annex confirms the obligation’s removal. The EU annex must detail the end-to-end process for data collection, analysis, and publication of the RTS 28 report for EU-facing business. |
| Dark Pool Trading (Volume Caps) | The Double Volume Cap (DVC) mechanism, which limited the amount of trading in dark pools, was removed by the UK in 2023 to promote liquidity. | The EU is transitioning from the DVC to a Single Volume Cap mechanism, maintaining its policy of limiting trading in non-transparent venues to push more flow to lit markets. | The firm’s venue selection logic within its smart order router (SOR) must be calibrated differently for UK and EU orders. The policy must document this differentiation to justify venue choices in each jurisdiction. |
| Research Payments (Unbundling) | Rules have been relaxed. Bundled payments for research and execution are now permissible for SMEs below a £200m market cap and for FICC research. | The EU has made some “quick fix” adjustments, primarily for smaller market cap companies (below €1bn), but the principle of unbundling remains more broadly intact than in the UK. | The policy must define separate processes for the procurement and payment of research in the UK and EU, ensuring that payment structures (bundled or unbundled) align with the specific rules of the jurisdiction where the service is received. |

![Sleek, metallic, modular hardware with visible circuit elements, symbolizing the market microstructure for institutional digital asset derivatives. This low-latency infrastructure supports RFQ protocols, enabling high-fidelity execution for private quotation and block trade settlement, ensuring capital efficiency within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/08/market-microstructure-engine-for-crypto-derivatives-rfq-protocol.jpg)

![Stacked, modular components represent a sophisticated Prime RFQ for institutional digital asset derivatives. Each layer signifies distinct liquidity pools or execution venues, with transparent covers revealing intricate market microstructure and algorithmic trading logic, facilitating high-fidelity execution and price discovery within a private quotation environment](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-execution-framework.jpg)

## Execution

![Interconnected modular components with luminous teal-blue channels converge diagonally, symbolizing advanced RFQ protocols for institutional digital asset derivatives. This depicts high-fidelity execution, price discovery, and aggregated liquidity across complex market microstructure, emphasizing atomic settlement, capital efficiency, and a robust Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-microstructure-protocols.jpg)

## The Operational Playbook for Dual Compliance

Executing a dual-jurisdiction best [execution policy](https://prime.greeks.live/question/how-should-an-order-execution-policy-balance-the-need-for-information-control-against-the-duty-of-best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) requires a meticulously designed operational framework. The theoretical strategy of a “core and annex” model must be translated into tangible processes, system configurations, and governance workflows. The primary execution step is the formal drafting and approval of this structured policy. The core document should be drafted by a central compliance or risk function, with input from trading desks and technology teams.

It must then be formally ratified by the firm’s governing body. Subsequently, the UK and EU annexes must be developed by the respective local compliance teams, ensuring they accurately reflect the nuances of their specific regulatory environments. This process ensures both global consistency and local precision.

The next critical step is the operationalization of the policy within the firm’s trading infrastructure. This involves configuring the Order Management System (OMS) and Execution Management System (EMS) to support the bifurcated logic. For instance, the firm’s Smart Order Router (SOR) must be programmed with two distinct rule sets for venue selection. For an order booked in the UK, the SOR can access dark pools without the constraints of a volume cap.

For an identical order booked in an EU entity, the SOR must adhere to the EU’s Single Volume Cap mechanism. This requires sophisticated technological capabilities and a close working relationship between the compliance, trading, and technology departments to ensure the system’s logic perfectly mirrors the documented policy.

![A sophisticated modular apparatus, likely a Prime RFQ component, showcases high-fidelity execution capabilities. Its interconnected sections, featuring a central glowing intelligence layer, suggest a robust RFQ protocol engine](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-engine-core-for-digital-asset-derivatives-high-fidelity-execution-protocols.jpg)

## A Checklist for Implementing a Bifurcated Policy

Successfully implementing and maintaining a best execution framework that spans both the UK and the EU requires a structured, cyclical process. The following list outlines the key operational steps a firm must undertake to ensure its policy is robust, effective, and demonstrably compliant in both jurisdictions.

- **Policy Architecture and Drafting** ▴ 
Establish a working group with representation from Compliance, Legal, Trading, and Technology. This group will be tasked with drafting the core policy document, ensuring it captures the universal principles of best execution derived from the common MiFID II heritage. Following this, dedicated sub-groups for the UK and EU will draft the jurisdiction-specific annexes, focusing on areas of divergence like reporting and transparency rules.

- **System Calibration and Testing** ▴ 
Translate the policy’s rules into concrete system logic within the firm’s OMS, EMS, and SOR. This involves configuring distinct routing tables and venue prioritization models for UK- and EU-domiciled orders. A rigorous testing phase must be conducted, using hypothetical trade scenarios to validate that the systems execute according to the correct jurisdictional ruleset before the policy goes live.

- **Governance and Oversight Framework** ▴ 
Formally constitute a [Best Execution Committee](https://prime.greeks.live/area/best-execution-committee/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) with cross-functional representation. This committee will be responsible for the ongoing oversight of the policy’s effectiveness. Its terms of reference must explicitly include the review of monitoring reports from both the UK and EU operations, and it must meet on at least a quarterly basis to assess performance and address any identified issues.

- **Monitoring and Surveillance Configuration** ▴ 
Deploy a [transaction cost analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA) system capable of capturing and analyzing execution data according to the parameters of both regimes. For the EU, this system must be configured to gather the specific data points required for the annual RTS 28 report. For both jurisdictions, the system should generate regular exception reports that flag any deviations from the policy for review by the Best [Execution Committee](https://prime.greeks.live/question/how-does-a-best-execution-committee-quantify-and-compare-execution-quality-across-different-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

- **Staff Training and Certification** ▴ 
Develop and roll out a mandatory training program for all relevant staff, including traders, compliance officers, and operations personnel. The training must cover the core principles of the unified policy and provide specific modules on the divergent requirements detailed in the UK and EU annexes. A certification process should be implemented to ensure and document that all relevant personnel understand their responsibilities under the framework.

- **Annual Policy Review and Attestation** ▴ 
Institute a formal annual review process for the entire policy framework. This review must assess the continued appropriateness of the execution factors, the performance of approved venues, and the accuracy of the system’s logic. The process should conclude with a formal attestation by the heads of the UK and EU entities, confirming that the policy remains fit for purpose and compliant with all current local regulations.

![A sleek, modular institutional grade system with glowing teal conduits represents advanced RFQ protocol pathways. This illustrates high-fidelity execution for digital asset derivatives, facilitating private quotation and efficient liquidity aggregation](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-ecosystem-powering-high-fidelity-rfq-execution-and-optimal-liquidity-discovery.jpg)

## Quantitative Monitoring and Data Analysis

The cornerstone of any credible best execution framework is a robust, data-driven monitoring program. For a firm operating under both UK and EU rules, this means implementing a Transaction [Cost Analysis](https://prime.greeks.live/area/cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA) system that is both comprehensive and adaptable. The system must capture a wide array of data points for every order, from the moment of receipt to final settlement. This data forms the raw material for assessing execution quality and demonstrating compliance.

While the core analytical techniques, such as comparing execution prices to arrival prices or various benchmarks (e.g. VWAP, TWAP), will be consistent across both jurisdictions, the emphasis and reporting outputs will differ.

For the EU-facing business, the TCA system must be specifically configured to generate the quantitative data required for the RTS 28 report. This involves tagging trades by asset class and client type, and systematically compiling statistics on the top five execution venues used. For the UK operation, while the formal report is no longer required, the underlying analysis remains a critical component of the firm’s general obligation to monitor the effectiveness of its arrangements.

The data can be used to generate internal management information, providing the Best Execution Committee with the insights needed to challenge and refine venue selection and execution strategies. The key is a single, powerful data analytics engine that can be configured to produce different “views” of the data, tailored to the specific regulatory requirements and internal governance needs of each jurisdiction.

![A complex, multi-component 'Prime RFQ' core with a central lens, symbolizing 'Price Discovery' for 'Digital Asset Derivatives'. Dynamic teal 'liquidity flows' suggest 'Atomic Settlement' and 'Capital Efficiency'](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine.jpg)

## A Unified TCA Framework for Divergent Reporting

The table below presents a hypothetical TCA framework designed to support a dual UK/EU best execution policy. It illustrates how a single set of captured data points can be utilized to satisfy both the internal governance needs of the UK entity and the explicit regulatory reporting requirements of the EU entity. The “Primary Use Case” column highlights where the analytical output is directed.

| Data Point / Metric | Definition | Primary Use Case (UK) | Primary Use Case (EU) |
| --- | --- | --- | --- |
| Arrival Price | The mid-price of the instrument at the time the order is received by the firm. | Internal performance benchmark for calculating price slippage. Used by the Best Execution Committee to assess SOR effectiveness. | Core benchmark for internal monitoring and demonstrating that price, as a key factor, is being effectively managed. |
| Execution Price Slippage | (Average Execution Price – Arrival Price) / Arrival Price. Measures the price movement between order receipt and execution. | Key performance indicator (KPI) for internal venue and algorithm analysis. Helps identify market impact. | A critical metric for the summary of execution outcomes required within the RTS 28 report. |
| Explicit Costs | All documented commissions, fees (venue, clearing, settlement), and taxes associated with the trade. | Used to calculate the net execution performance for internal review. Essential for assessing the total cost of execution. | Mandatory data point for the RTS 28 report, which requires a summary of costs associated with execution. |
| Venue Execution Volume | The total volume and number of trades executed at each venue, categorized by asset class. | Internal analysis to ensure appropriate diversification of venues and to monitor for over-reliance on any single liquidity source. | The fundamental data required to compile the “Top 5 Execution Venues” list for the annual RTS 28 report. |
| Rejection Rates | The percentage of orders sent to a venue that are rejected or not filled. | A key metric for assessing the “Likelihood of Execution” factor. High rejection rates may trigger a venue review. | Supports the qualitative summary of execution quality in the RTS 28 report, explaining the firm’s venue choices. |
| Order Latency | The time elapsed between different stages of the order lifecycle (e.g. receipt to routing, routing to execution). | Internal KPI for monitoring the “Speed” factor and assessing the technical performance of the firm’s trading systems. | A supporting metric for the qualitative assessment within the RTS 28 report, demonstrating attention to the speed of execution. |
| Passive/Aggressive Ratio | The ratio of orders that provide liquidity (passive) versus those that take liquidity (aggressive) at a given venue. | Advanced internal metric used to analyze trading strategy effectiveness and implicit costs (spread capture). | Can be used to provide a more sophisticated qualitative narrative in the RTS 28 report about how execution strategy is tailored. |

![The central teal core signifies a Principal's Prime RFQ, routing RFQ protocols across modular arms. Metallic levers denote precise control over multi-leg spread execution and block trades](https://options.greeks.live/wp-content/uploads/2025/07/principals-prime-os-rfq-system-institutional-digital-asset-derivatives.jpg)

## References

- Frase, Richard, Simon Wright, and Philippa List. “Brexit simplifies? FCA consultation on changes to UK MiFID’s conduct and organisational requirements.” Alternative Investment Management Association, 28 June 2021.

- Macfarlanes LLP. “The UK’s post-Brexit balancing act begins with MiFID II.” 14 May 2021.

- Global Compliance News. “UK ▴ FCA makes changes to MiFID II research rules and removes RTS 27 and RTS 28 best execution reporting.” 5 January 2022.

- eflow Global. “Best execution and beyond – What’s happening to RTS 27 & 28 post-Brexit?.” 31 March 2021.

- TRAction Fintech. “RTS 27 and 28 ▴ The 2024 Status of These Reports in UK and EU.” 14 February 2024.

- European Securities and Markets Authority. “MiFID II Review report on the development in prices for pre- and post-trade data and on the consolidated tape for equity instruments.” 2020.

- European Securities and Markets Authority. “Questions and Answers On MiFID II and MiFIR investor protection and intermediaries topics.” 2017.

- Financial Conduct Authority. “PS21/20 ▴ Reforms to UK MiFID’s conduct and organisational requirements.” November 2021.

![Modular institutional-grade execution system components reveal luminous green data pathways, symbolizing high-fidelity cross-asset connectivity. This depicts intricate market microstructure facilitating RFQ protocol integration for atomic settlement of digital asset derivatives within a Principal's operational framework, underpinned by a Prime RFQ intelligence layer](https://options.greeks.live/wp-content/uploads/2025/07/modular-high-fidelity-execution-architecture-for-institutional-digital-asset-derivatives-rfq-protocol-integration-and-principals-operational-framework-optimization.jpg)

## Reflection

![Intricate dark circular component with precise white patterns, central to a beige and metallic system. This symbolizes an institutional digital asset derivatives platform's core, representing high-fidelity execution, automated RFQ protocols, advanced market microstructure, the intelligence layer for price discovery, block trade efficiency, and portfolio margin](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-core.jpg)

## Building a Resilient Compliance Architecture

The challenge of maintaining a best execution policy across the UK and EU is a microcosm of a much larger theme in modern finance ▴ the management of regulatory fragmentation. The era of seamless harmonisation is being replaced by a more complex, multipolar regulatory world. For institutions that operate across these new divides, the response cannot be a patchwork of temporary fixes. Instead, it demands a fundamental shift in thinking, away from static, document-based compliance and towards the creation of a dynamic, resilient, and adaptable compliance architecture.

The framework described ▴ a consistent core policy underpinned by modular, jurisdiction-specific annexes ▴ is more than a solution to a single problem. It is a design pattern for the future. It acknowledges that while overarching principles may remain globally consistent, the methods of supervision, enforcement, and demonstration will continue to diverge.

A firm’s ability to thrive in this environment will depend on its capacity to build internal systems that can manage this complexity with elegance and efficiency. The ultimate strategic advantage lies not in simply complying with two sets of rules, but in architecting a single, intelligent system that can navigate any number of regulatory permutations without sacrificing its core commitment to market integrity and client success.

![Precision-engineered modular components display a central control, data input panel, and numerical values on cylindrical elements. This signifies an institutional Prime RFQ for digital asset derivatives, enabling RFQ protocol aggregation, high-fidelity execution, algorithmic price discovery, and volatility surface calibration for portfolio margin](https://options.greeks.live/wp-content/uploads/2025/07/firm-fx-options-rfq-trade-system-key-microstructure-data-flow-core-engine.jpg)

## Glossary

<a href="https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Stacked modular components with a sharp fin embody Market Microstructure for Digital Asset Derivatives. This represents High-Fidelity Execution via RFQ protocols, enabling Price Discovery, optimizing Capital Efficiency, and managing Gamma Exposure within an Institutional Prime RFQ for Block Trades](https://options.greeks.live/wp-content/uploads/2025/07/modular-system-for-institutional-digital-asset-derivatives-rfq-protocol-optimization.jpg)

## Best Execution

Meaning ▴ Best Execution is the obligation to obtain the most favorable terms reasonably available for a client's order. </a><a href="https://prime.greeks.live/area/fca/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A metallic disc, reminiscent of a sophisticated market interface, features two precise pointers radiating from a glowing central hub. This visualizes RFQ protocols driving price discovery within institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-price-discovery.jpg)

## Fca

Meaning ▴ The Financial Conduct Authority (FCA) operates as the primary regulatory body in the United Kingdom, holding the mandate to oversee the conduct of financial services firms and financial markets, including their engagement with digital assets. </a><a href="https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract dual-cone object reflects RFQ Protocol dynamism. It signifies robust Liquidity Aggregation, High-Fidelity Execution, and Principal-to-Principal negotiation](https://options.greeks.live/wp-content/uploads/2025/08/institutional-grade-rfq-execution-framework-for-digital-asset-derivatives-optimal-liquidity-aggregation-and-atomic-settlement.jpg)

## Mifid Ii

Meaning ▴ MiFID II, the Markets in Financial Instruments Directive II, constitutes a comprehensive regulatory framework enacted by the European Union to govern financial markets, investment firms, and trading venues. </a><a href="https://prime.greeks.live/question/how-does-mifid-ii-define-the-execution-factors-for-determining-best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered blue mechanism, symbolizing a high-fidelity execution engine, emerges from a rounded, light-colored liquidity pool component, encased within a sleek teal institutional-grade shell. This represents a Principal's operational framework for digital asset derivatives, demonstrating algorithmic trading logic and smart order routing for block trades via RFQ protocols, ensuring atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-os-core-algorithmic-execution-engine.jpg)

## Execution Factors

MiFID II defines best execution factors as a holistic set of variables for achieving the optimal, context-dependent result for a client. </a><a href="https://prime.greeks.live/question/how-does-a-best-execution-committee-quantify-and-compare-execution-quality-across-different-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated proprietary system module featuring precision-engineered components, symbolizing an institutional-grade Prime RFQ for digital asset derivatives. Its intricate design represents market microstructure analysis, RFQ protocol integration, and high-fidelity execution capabilities, optimizing liquidity aggregation and price discovery for block trades within a multi-leg spread environment](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-proprietary-architecture-driving-high-fidelity-digital-asset-derivatives-execution-via-rfq-protocols-and-optimized-market-microstructure-dynamics.jpg)

## Execution Venues

A Best Execution Committee systematically architects superior trading outcomes by quantifying performance against multi-dimensional benchmarks and comparing venues through rigorous, data-driven analysis. </a><a href="https://prime.greeks.live/question/how-does-an-rfq-platform-differentiate-between-on-venue-and-off-venue-reporting-obligations/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Beige and teal angular modular components precisely connect on black, symbolizing critical system integration for a Principal's operational framework. This represents seamless interoperability within a Crypto Derivatives OS, enabling high-fidelity execution, efficient price discovery, and multi-leg spread trading via RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-rfq-execution-microstructure-os-interop.jpg)

## Venue Selection

An RFQ platform differentiates reporting by codifying MiFIR's hierarchy, assigning on-venue reports to the venue and off-venue reports to the correct counterparty based on SI status. </a><a href="https://prime.greeks.live/question/how-does-the-2002-isda-framework-influence-the-negotiation-of-credit-support-annexes/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Modular plates and silver beams represent a Prime RFQ for digital asset derivatives. This principal's operational framework optimizes RFQ protocol for block trade high-fidelity execution, managing market microstructure and liquidity pools](https://options.greeks.live/wp-content/uploads/2025/08/digital-asset-derivatives-rfq-protocols-principal-execution-layer.jpg)

## Jurisdiction-Specific Annexes

The 2002 ISDA framework imposes a disciplined risk architecture that elevates CSA negotiations from a task to a core strategic function. </a><a href="https://prime.greeks.live/area/regulatory-divergence/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A stacked, multi-colored modular system representing an institutional digital asset derivatives platform. The top unit facilitates RFQ protocol initiation and dynamic price discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-15.jpg)

## Regulatory Divergence

Meaning ▴ Regulatory Divergence refers to the structural inconsistencies in legal and supervisory frameworks governing financial activities, particularly within the nascent and evolving domain of institutional digital asset derivatives, across distinct sovereign jurisdictions. </a><a href="https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A metallic structural component interlocks with two black, dome-shaped modules, each displaying a green data indicator. This signifies a dynamic RFQ protocol within an institutional Prime RFQ, enabling high-fidelity execution for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/modular-rfq-protocol-engine-for-digital-asset-derivatives-prime-os.jpg)

## Rts 27

Meaning ▴ RTS 27 mandates that investment firms and market operators publish detailed data on the quality of execution of transactions on their venues. </a><a href="https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek Prime RFQ component extends towards a luminous teal sphere, symbolizing Liquidity Aggregation and Price Discovery for Institutional Digital Asset Derivatives. This represents High-Fidelity Execution via RFQ Protocol within a Principal's Operational Framework, optimizing Market Microstructure](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-execution-for-institutional-digital-asset-derivatives.jpg)

## Rts 28

Meaning ▴ RTS 28 refers to Regulatory Technical Standard 28 under MiFID II, which mandates investment firms and market operators to publish annual reports on the quality of execution of transactions on trading venues and for financial instruments. </a><a href="https://prime.greeks.live/area/volume-cap/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An exploded view reveals the precision engineering of an institutional digital asset derivatives trading platform, showcasing layered components for high-fidelity execution and RFQ protocol management. This architecture facilitates aggregated liquidity, optimal price discovery, and robust portfolio margin calculations, minimizing slippage and counterparty risk](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-execution-engine-microstructure.jpg)

## Volume Cap

Meaning ▴ A Volume Cap defines a predefined maximum quantity of a specific digital asset derivative that an execution system is permitted to trade within a designated time interval or through a particular venue. </a><a href="https://prime.greeks.live/area/best-execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Modular circuit panels, two with teal traces, converge around a central metallic anchor. This symbolizes core architecture for institutional digital asset derivatives, representing a Principal's Prime RFQ framework, enabling high-fidelity execution and RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-engine-prime-os.jpg)

## Best Execution Policy

Meaning ▴ The Best Execution Policy defines the obligation for a broker-dealer or trading firm to execute client orders on terms most favorable to the client. </a><a href="https://prime.greeks.live/question/how-should-an-order-execution-policy-balance-the-need-for-information-control-against-the-duty-of-best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, open system showcases modular architecture, embodying an institutional-grade Prime RFQ for digital asset derivatives. Distinct internal components signify liquidity pools and multi-leg spread capabilities, ensuring high-fidelity execution via RFQ protocols for price discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-modularity-unveiled.jpg)

## Execution Policy

An Order Execution Policy architects the trade-off between information control and best execution to protect value while seeking liquidity. </a><a href="https://prime.greeks.live/area/best-execution-committee/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precisely balanced transparent sphere, representing an atomic settlement or digital asset derivative, rests on a blue cross-structure symbolizing a robust RFQ protocol or execution management system. This setup is anchored to a textured, curved surface, depicting underlying market microstructure or institutional-grade infrastructure, enabling high-fidelity execution, optimized price discovery, and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-engineered-rfq-block-trade-execution-for-digital-asset-derivatives.jpg)

## Best Execution Committee

Meaning ▴ The Best Execution Committee functions as a formal governance body within an institutional trading framework, specifically mandated to define, implement, and continuously monitor policies and procedures ensuring optimal trade execution across all asset classes, including institutional digital asset derivatives. </a><a href="https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract metallic and dark components symbolize complex market microstructure and fragmented liquidity pools for digital asset derivatives. A smooth disc represents high-fidelity execution and price discovery facilitated by advanced RFQ protocols on a robust Prime RFQ, enabling precise atomic settlement for institutional multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-market-microstructure-optimizing-rfq-protocols-for-high-fidelity-execution-on-prime-os.jpg)

## Transaction Cost Analysis

Meaning ▴ Transaction Cost Analysis (TCA) is the quantitative methodology for assessing the explicit and implicit costs incurred during the execution of financial trades. </a><a href="https://prime.greeks.live/question/how-does-a-best-execution-committee-quantify-and-compare-execution-quality-across-different-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A polished metallic modular hub with four radiating arms represents an advanced RFQ execution engine. This system aggregates multi-venue liquidity for institutional digital asset derivatives, enabling high-fidelity execution and precise price discovery across diverse counterparty risk profiles, powered by a sophisticated intelligence layer](https://options.greeks.live/wp-content/uploads/2025/08/principal-rfq-hub-digital-asset-derivatives-liquidity-aggregation.jpg)

## Execution Committee

A Best Execution Committee systematically architects superior trading outcomes by quantifying performance against multi-dimensional benchmarks and comparing venues through rigorous, data-driven analysis. </a><a href="https://prime.greeks.live/area/cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An abstract view reveals the internal complexity of an institutional-grade Prime RFQ system. Glowing green and teal circuitry beneath a lifted component symbolizes the Intelligence Layer powering high-fidelity execution for RFQ protocols and digital asset derivatives, ensuring low latency atomic settlement](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-prime-os-core-engine-for-rfq-protocol-execution.jpg)

## Cost Analysis

Meaning ▴ Cost Analysis constitutes the systematic quantification and evaluation of all explicit and implicit expenditures incurred during a financial operation, particularly within the context of institutional digital asset derivatives trading. </a>

**Tags:** [RTS 27](https://options.greeks.live/area/rts-27/), [Smart Order Routing](https://options.greeks.live/area/smart-order-routing/), [Best Execution Committee](https://options.greeks.live/area/best-execution-committee/), [MiFID II](https://options.greeks.live/area/mifid-ii/), [Cost Analysis](https://options.greeks.live/area/cost-analysis/), [UK MiFID](https://options.greeks.live/area/uk-mifid/)	

## Discover More

- 
### [What Are the Primary Data Requirements for Building a Defensible Best Execution Dossier?](https://options.greeks.live/question/what-are-the-primary-data-requirements-for-building-a-defensible-best-execution-dossier/)
![A central metallic bar, representing an RFQ block trade, pivots through translucent geometric planes symbolizing dynamic liquidity pools and multi-leg spread strategies. This illustrates a Principal's operational framework for high-fidelity execution and atomic settlement within a sophisticated Crypto Derivatives OS, optimizing private quotation workflows.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-facilitating-high-fidelity-price-discovery-and-optimal-capital-efficiency-within-advanced-market-microstructure.jpg)

A defensible best execution dossier is a data-driven narrative substantiating optimal trade-offs between price, cost, and speed.

- 
### [What Are the Primary Technological Challenges in Complying with MiFID II’s Best Execution Requirements?](https://options.greeks.live/question/what-are-the-primary-technological-challenges-in-complying-with-mifid-iis-best-execution-requirements/)
![A sophisticated, angular digital asset derivatives execution engine with glowing circuit traces and an integrated chip rests on a textured platform. This symbolizes advanced RFQ protocols, high-fidelity execution, and the robust Principal's operational framework supporting institutional-grade market microstructure and optimized liquidity aggregation.](https://options.greeks.live/wp-content/uploads/2025/08/advanced-digital-asset-derivatives-rfq-protocol-engine-architecture.jpg)

MiFID II best execution compliance demands an integrated data architecture to prove optimal outcomes across a vector of performance factors.

- 
### [How Has the Removal of RTS 27 and RTS 28 Reports Affected Best Execution Obligations in the Uk and Eu?](https://options.greeks.live/question/how-has-the-removal-of-rts-27-and-rts-28-reports-affected-best-execution-obligations-in-the-uk-and-eu/)
![A sophisticated teal and black device with gold accents symbolizes a Principal's operational framework for institutional digital asset derivatives. It represents a high-fidelity execution engine, integrating RFQ protocols for atomic settlement. This intelligence layer optimizes price discovery, managing portfolio margin and ensuring best execution in market microstructure.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-core-engine-for-best-execution.jpg)

The removal of RTS 27/28 reporting reframes best execution from a compliance artifact to a core, data-driven operational discipline.

- 
### [How Has MiFID II Changed Best Execution Requirements for Fixed Income?](https://options.greeks.live/question/how-has-mifid-ii-changed-best-execution-requirements-for-fixed-income/)
![A teal-blue disk, symbolizing a liquidity pool for digital asset derivatives, is intersected by a bar. This represents an RFQ protocol or block trade, detailing high-fidelity execution pathways. The interaction illustrates price discovery and market microstructure dynamics, central to a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocols-high-fidelity-digital-asset-execution.jpg)

MiFID II transformed fixed income best execution from a qualitative judgment into a data-driven, provable discipline.

- 
### [What Are the Key Technological Requirements for a Firm to Comply with MiFID II Best Execution?](https://options.greeks.live/question/what-are-the-key-technological-requirements-for-a-firm-to-comply-with-mifid-ii-best-execution/)
![A sophisticated mechanism depicting the high-fidelity execution of institutional digital asset derivatives. It visualizes RFQ protocol efficiency, real-time liquidity aggregation, and atomic settlement within a prime brokerage framework, optimizing market microstructure for multi-leg spreads.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-protocol-execution-liquidity-aggregation-system.jpg)

A firm's compliance with MiFID II best execution hinges on an integrated technological system for data capture, analysis, and auditable proof of optimal outcomes.

- 
### [What Is the Role of a Best Execution Committee in a Firm’s Governance Structure?](https://options.greeks.live/question/what-is-the-role-of-a-best-execution-committee-in-a-firms-governance-structure/)
![A modular, institutional-grade device with a central data aggregation interface and metallic spigot. This Prime RFQ represents a robust RFQ protocol engine, enabling high-fidelity execution for institutional digital asset derivatives, optimizing capital efficiency and best execution.](https://options.greeks.live/wp-content/uploads/2025/08/principals-institutional-digital-asset-derivatives-prime-os-for-optimized-rfq-protocol-best-execution-system.jpg)

A Best Execution Committee is a firm's governance nucleus for ensuring trade execution is strategically optimized, compliant, and defensible.

- 
### [How Can a TCA Framework Help Institutions Meet Best Execution Requirements under MiFID II?](https://options.greeks.live/question/how-can-a-tca-framework-help-institutions-meet-best-execution-requirements-under-mifid-ii/)
![A central core, symbolizing a Crypto Derivatives OS and Liquidity Pool, is intersected by two abstract elements. These represent Multi-Leg Spread and Cross-Asset Derivatives executed via RFQ Protocol. This visual embodies High-Fidelity Execution within an Institutional Trading framework, emphasizing Market Microstructure and Capital Efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-protocol-multi-leg-spread-execution.jpg)

A TCA framework translates execution data into verifiable proof, embedding MiFID II compliance directly into an institution's operational core.

- 
### [How Does the Management of Conflicts of Interest Impact Best Execution Documentation?](https://options.greeks.live/question/how-does-the-management-of-conflicts-of-interest-impact-best-execution-documentation/)
![A spherical, eye-like structure, an Institutional Prime RFQ, projects a sharp, focused beam. This visualizes high-fidelity execution via RFQ protocols for digital asset derivatives, enabling block trades and multi-leg spreads with capital efficiency and best execution across market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-prime-os-rfq-protocol-digital-asset-derivatives-block-trade-execution.jpg)

Effective conflict management transforms best execution documentation from a regulatory burden into a verifiable record of a firm's commitment to client interests.

- 
### [What Are the Key Components of a MiFID II Compliant Best Execution Policy?](https://options.greeks.live/question/what-are-the-key-components-of-a-mifid-ii-compliant-best-execution-policy/)
![Precision-engineered institutional grade components, representing prime brokerage infrastructure, intersect via a translucent teal bar embodying a high-fidelity execution RFQ protocol. This depicts seamless liquidity aggregation and atomic settlement for digital asset derivatives, reflecting complex market microstructure and efficient price discovery.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-prime-os-core.jpg)

A MiFID II best execution policy is the operational blueprint for a firm's fiduciary duty, systematically translating market data into auditable, optimal client outcomes.

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---

**Original URL:** https://options.greeks.live/question/can-a-single-best-execution-policy-satisfy-both-the-fca-and-an-eu-national-competent-authority/
