# How Do SIs Alter the Calculation of Best Execution under MiFID II? ▴ Question

**Published:** 2025-08-05
**Categories:** Question

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## Concept

The introduction of the [Systematic Internaliser](https://prime.greeks.live/area/systematic-internaliser/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (SI) regime under MiFID II represents a fundamental redesign of the market’s data architecture. Your existing [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) framework, calibrated for a world of centralized, lit exchanges and multilateral trading facilities (MTFs), now confronts a new, parallel liquidity universe. This universe operates on a bilateral basis, where investment firms execute client orders against their own book.

The core challenge this presents is one of observation and integration. An [execution policy](https://prime.greeks.live/area/execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) that fails to incorporate SI quote data is, in effect, operating with a significant blind spot, unaware of potentially superior prices offered in these private channels.

The SI framework compels certain high-volume investment firms to formalize their over-the-counter (OTC) activities, bringing them into a regulated and transparent structure. For instruments they trade frequently and in substantial size, these firms must provide firm, executable quotes to their clients. This creates a stream of pre-trade data that was previously inaccessible or inconsistent. The alteration to your best execution calculation, therefore, begins before a single order is routed.

It begins with the systemic requirement to capture, analyze, and act upon this new source of [pre-trade transparency](https://prime.greeks.live/area/pre-trade-transparency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). Your analytical models must now weigh the firm, bilateral quotes from an SI against the dynamic, all-to-all liquidity available on a public exchange.

> A firm’s best execution capability is now directly proportional to its ability to process and compare fragmented, bilateral data streams alongside public market data.

This shift moves the point of execution analysis from a purely public-facing activity to a hybrid one. The question is no longer just “what is the best price on the public markets?” but “what is the best available price across all permissible execution venues, including the private quotes from our SI counterparties?” This necessitates a profound change in both technology and process. Your [Smart Order](https://prime.greeks.live/question/how-does-a-smart-order-router-prioritize-different-venue-types-when-executing-a-large-order/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Routers (SORs) and execution algorithms require reprogramming to ingest and intelligently rank SI quotes.

Your compliance oversight must evolve to monitor and evidence that these new venues are being fairly considered and that they are, over time, contributing positively to [execution quality](https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) for your clients. The SI is a structural intervention that redefines what it means to have a complete view of the market.

![Intersecting concrete structures symbolize the robust Market Microstructure underpinning Institutional Grade Digital Asset Derivatives. Dynamic spheres represent Liquidity Pools and Implied Volatility](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-framework-optimizing-rfq-execution-and-liquidity-for-principal-trading.jpg)

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## Strategy

Adapting a best [execution strategy](https://prime.greeks.live/area/execution-strategy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to the realities of the SI regime requires a move from a static, venue-centric model to a dynamic, data-centric one. The core strategic objective is to build an analytical framework that can systematically compare heterogeneous liquidity pools ▴ the central limit order books of regulated markets and the bilateral quote streams of SIs ▴ and make an optimal routing decision in real-time. This is a considerable architectural challenge that impacts technology, compliance, and trading workflows.

![A dark central hub with three reflective, translucent blades extending. This represents a Principal's operational framework for digital asset derivatives, processing aggregated liquidity and multi-leg spread inquiries](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-protocol-engine-for-high-fidelity-digital-asset-derivatives.jpg)

## Recalibrating the Execution Venue Analysis

The traditional four-fold test for best execution ▴ price, costs, speed, and likelihood of execution ▴ remains the guiding principle. However, SIs introduce new variables into each component of this test. A strategic response involves updating the firm’s execution policy to explicitly define how these variables are weighted and measured when an SI is a potential venue.

- **Price** ▴ An SI provides a firm quote, which can be advantageous for certainty of execution. This price may also include improvements over the prevailing public market bid-offer spread. The strategy must involve capturing these quotes and comparing them to the European Best Bid and Offer (EBBO) at the moment of execution.

- **Costs** ▴ Execution on an SI typically avoids exchange or clearing fees. These implicit cost savings must be quantified and factored into the total consideration calculation, which is the ultimate measure of best execution.

- **Speed** ▴ Bilateral execution with an SI can be faster, as it removes the latency associated with an order resting on a public book. This is particularly relevant for latency-sensitive strategies.

- **Likelihood of Execution** ▴ For large orders (above standard market size), an SI can offer a higher probability of full execution without market impact, as the trade occurs off-book. The strategic assessment must consider the risk of information leakage and slippage on a lit venue versus the certainty offered by an SI.

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## How Does Pre-Trade Transparency from SIs Change Routing Logic?

The mandate for SIs to publish pre-trade quotes for liquid instruments underpins the entire strategic shift. This data cannot remain passive. It must be actively integrated into the firm’s [Smart Order Router](https://prime.greeks.live/area/smart-order-router/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (SOR) logic. Imagine the SOR as a GPS for your orders.

Previously, it navigated a map of public highways (exchanges, MTFs). Now, it must also see a network of private, high-speed toll roads (SIs).

The SOR’s algorithm must be enhanced to send a request-for-quote (RFQ) to relevant SIs concurrently with checking the [lit market](https://prime.greeks.live/area/lit-market/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) prices. The routing decision is then based on the superior result returned from all sources. This requires a technical build-out to establish and maintain FIX protocol connections to multiple SIs and a logical upgrade to the SOR to process the returned quote data within the order’s execution timeframe. The strategy here is one of technological parity; your firm’s internal systems must be able to “speak the language” of SIs to access their liquidity.

> Integrating SI quote streams transforms the Smart Order Router from a passive price-taker on public markets to an active liquidity seeker across a hybrid market structure.

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## Integrating Bilateral and Public Data Streams

A successful strategy hinges on creating a unified view of a fragmented market. It is useful to conceptualize lit markets as a vast, open public square where all participants can see the ongoing auction. SIs, in this analogy, are a series of private, sound-proofed rooms where a firm can receive a direct, binding price from a counterparty. A robust best execution strategy ensures the trader has a window into every relevant room while still watching the main square.

This requires a data management strategy capable of normalizing and synchronizing these different data types. The public market provides a continuous stream of Level 2 data, while SIs provide discrete, on-demand quotes. The following table illustrates the strategic considerations when comparing these liquidity sources.

| Execution Factor | Lit Market (e.g. Regulated Market) | Systematic Internaliser (SI) |
| --- | --- | --- |
| Price Discovery | Multilateral and transparent, contributing to public price formation. | Bilateral; price is based on the SI’s own risk position and the public reference price. |
| Pre-Trade Transparency | Publicly disseminated order book (e.g. Level 2 data). | Firm quotes provided upon request to clients. Public disclosure for liquid instruments. |
| Execution Certainty | Dependent on order queue priority and available depth. | High certainty up to the quoted size, as the SI is the direct counterparty. |
| Market Impact | Higher potential for information leakage and slippage, especially for large orders. | Minimal to zero market impact, as the trade is executed off-book. |
| Associated Costs | Includes exchange fees, clearing fees, and potential broker commissions. | Typically embedded in the spread; avoids explicit venue and clearing fees. |

The strategic implementation involves building a system that can weigh these factors on a trade-by-trade basis, guided by the overarching execution policy. This ensures that the choice of venue is not just compliant, but is demonstrably in the best interest of the client based on a holistic and evidence-based assessment of all available liquidity sources.

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## Execution

The execution of a best execution policy that properly incorporates Systematic Internalisers is a matter of precise operational engineering. It demands a granular approach to technology integration, quantitative analysis, and regulatory reporting. The abstract strategy must be translated into a concrete, auditable workflow that proves the firm is taking all sufficient steps to achieve the best possible result for its clients on a consistent basis.

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## The Operational Playbook for SI Integration

Integrating SIs into an existing execution framework is a multi-stage process that touches every part of the trading lifecycle. The following steps provide a high-level operational playbook for a firm seeking to systematically leverage SI liquidity.

- **Venue Identification and Onboarding** ▴ The firm must first identify the investment firms that have registered as SIs for the specific asset classes and instruments it trades. This involves reviewing regulatory registers and engaging directly with counterparties. An onboarding process must then be initiated, which includes due diligence on the SI’s execution quality and establishing the necessary legal and commercial agreements.

- **Technological Connectivity** ▴ Secure and low-latency connectivity must be established. This is typically achieved via the Financial Information eXchange (FIX) protocol. The firm’s [order management system](https://prime.greeks.live/area/order-management-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (OMS) and execution management system (EMS) must be configured with the correct FIX message specifications to request quotes from and route orders to the SI.

- **Smart Order Router (SOR) Calibration** ▴ The logic of the SOR is the core of the execution process. It must be recalibrated to recognize SIs as a distinct venue type. The SOR’s algorithm needs to be programmed to query SIs for quotes in parallel with scanning lit market order books and to make a routing decision based on a weighted analysis of the best execution factors defined in the firm’s policy.

- **[Transaction Cost Analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA) Model Enhancement** ▴ Post-trade analysis is critical for demonstrating best execution. The firm’s TCA model must be enhanced to properly benchmark SI executions. This means capturing not only the execution price but also the lit market reference price (e.g. arrival price or Volume-Weighted Average Price – VWAP) at the time of the SI trade. This allows for a quantitative comparison of the execution quality provided by the SI versus other venues.

- **Compliance Monitoring and Reporting** ▴ The compliance function requires new tools to monitor SI-related order flow. This includes building surveillance reports to ensure that SIs are being given fair consideration and to track their performance over time. Furthermore, the data from SI executions must be fed into the annual [RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) reporting process, which discloses the top five execution venues used for each class of financial instrument.

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## Quantitative Modeling and Data Analysis

A data-driven approach is essential to validating the effectiveness of an SI-inclusive execution strategy. This requires specific quantitative models both pre-trade and post-trade. The pre-trade model, embedded within the SOR, must calculate the expected total consideration from each potential venue, while the post-trade TCA model must measure the actual outcome.

> Effective execution requires a quantitative framework that can translate the abstract principles of best execution into measurable, comparable data points across all venue types.

The table below provides a simplified model of a pre-trade SOR weighting mechanism. It demonstrates how a system might quantify the decision-making process.

| Metric | Regulated Market | Systematic Internaliser | Weighting Factor |
| --- | --- | --- | --- |
| Reference Price (EUR) | 100.05 (Best Offer) | 100.04 (Firm Quote) | 60% |
| Expected Fees (bps) | 0.50 | 0.00 | 20% |
| Expected Latency (ms) | 50 | 10 | 10% |
| Expected Fill Rate (%) | 85% (for order size) | 100% (up to quote size) | 10% |
| Weighted Score | | | 100% |

In a post-trade context, a detailed TCA report is the primary evidence of best execution. The following table illustrates a comparative analysis of two hypothetical trades, demonstrating how the performance of an SI is measured.

| Order ID | Asset | Venue | Execution Price | Arrival Price | Slippage (bps) | Fees (EUR) | Total Cost (bps) |
| --- | --- | --- | --- | --- | --- | --- | --- |
| ORD-001 | ABC Corp | Lit Exchange | 100.10 | 100.05 | +5.0 | 5.00 | +5.5 |
| ORD-002 | ABC Corp | SI-Bank-A | 100.04 | 100.05 | -1.0 | 0.00 | -1.0 |

This quantitative analysis provides the audit trail necessary to justify execution decisions to both clients and regulators. It moves the concept of best execution from a qualitative statement of intent to a quantitative, evidence-based practice.

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## What Is the Consequence for Regulatory Reporting?

The inclusion of SIs has a direct and significant impact on a firm’s reporting obligations, particularly the annual RTS 28 report. This report requires a firm to publish, for each class of financial instruments, its top five execution venues in terms of trading volumes. When a firm executes a significant volume of trades with SIs, those SIs will likely feature prominently in this report. This has several consequences.

First, it increases the transparency of the firm’s execution practices, making its choice of counterparties public. Second, it requires the firm to write a detailed summary of the execution quality obtained from these venues, justifying why routing flow to a bilateral counterparty was consistent with its best execution duty. This narrative must be supported by the quantitative TCA data gathered throughout the year, creating a direct link between daily execution practice and annual regulatory disclosure.

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## References

- ICMA. (2018). MiFID II SI Regime Workshops A summary report. International Capital Market Association.

- Callaghan, E. (2016). MiFID II/MiFIR ▴ Transparency & Best Execution requirements in respect of bonds. International Capital Market Association.

- Swedish Securities Dealers Association. (2018). Guide for drafting/review of Execution Policy under MiFID II.

- Autorité des marchés financiers. (2020). Summary document on SPOT inspections of the best execution and best selection obligations applicable to asset management companies.

- Deutsche Bank Wealth Management. (2022). EMEA Order Execution Policy 2022.

- European Securities and Markets Authority. (2017). Questions and Answers on MiFID II and MiFIR investor protection and intermediaries topics. ESMA70-872942901-38.

- Lehalle, C. A. & Laruelle, S. (Eds.). (2013). Market Microstructure in Practice. World Scientific Publishing.

- Harris, L. (2003). Trading and Exchanges ▴ Market Microstructure for Practitioners. Oxford University Press.

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## Reflection

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## Is Your Data Architecture a Window or a Wall?

The integration of Systematic Internalisers into the European market structure was an architectural intervention designed to illuminate the OTC space. It forces a critical question upon every investment firm ▴ is your current operational framework designed to look through this new window, or does it treat it as a wall? A legacy system, calibrated only for public exchange data, cannot perceive the liquidity and pricing information that now exists beyond its narrow view.

Achieving a superior execution outcome in the current market is a function of observational capacity. The challenge is to ensure your firm’s technological and analytical architecture provides a complete, panoramic view of all available liquidity, enabling your execution strategy to be truly systematic and demonstrably optimal.

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## Glossary

<a href="https://prime.greeks.live/area/systematic-internaliser/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Systematic Internaliser

Meaning ▴ A Systematic Internaliser (SI) is a financial institution executing client orders against its own capital on an organized, frequent, systematic basis off-exchange. </a><a href="https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central RFQ aggregation engine radiates segments, symbolizing distinct liquidity pools and market makers. This depicts multi-dealer RFQ protocol orchestration for high-fidelity price discovery in digital asset derivatives, highlighting diverse counterparty risk profiles and algorithmic pricing grids](https://options.greeks.live/wp-content/uploads/2025/07/centralized-digital-asset-rfq-orchestration-for-multi-venue-liquidity-aggregation-and-high-fidelity-execution-across-diverse-counterparties.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/execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Execution Policy

Meaning ▴ An Execution Policy defines a structured set of rules and computational logic governing the handling and execution of financial orders within a trading system. </a><a href="https://prime.greeks.live/area/pre-trade-transparency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Pre-Trade Transparency

Meaning ▴ Pre-Trade Transparency refers to the real-time dissemination of bid and offer prices, along with associated sizes, prior to the execution of a trade. </a><a href="https://prime.greeks.live/question/how-does-a-smart-order-router-prioritize-different-venue-types-when-executing-a-large-order/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Smart Order

A Smart Order Router executes large orders by systematically navigating fragmented liquidity, prioritizing venues based on a dynamic optimization of cost, speed, and market impact. </a><a href="https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Execution Quality

Meaning ▴ Execution Quality quantifies the efficacy of an order's fill, assessing how closely the achieved trade price aligns with the prevailing market price at submission, alongside consideration for speed, cost, and market impact. </a><a href="https://prime.greeks.live/area/execution-strategy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Two distinct components, beige and green, are securely joined by a polished blue metallic element. This embodies a high-fidelity RFQ protocol for institutional digital asset derivatives, ensuring atomic settlement and optimal liquidity](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-protocol-for-digital-asset-derivatives-high-fidelity-link.jpg)

## Execution Strategy

Meaning ▴ A defined algorithmic or systematic approach to fulfilling an order in a financial market, aiming to optimize specific objectives like minimizing market impact, achieving a target price, or reducing transaction costs. </a><a href="https://prime.greeks.live/area/smart-order-router/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Smart Order Router

Meaning ▴ A Smart Order Router (SOR) is an algorithmic trading mechanism designed to optimize order execution by intelligently routing trade instructions across multiple liquidity venues. </a><a href="https://prime.greeks.live/area/lit-market/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Lit Market

Meaning ▴ A lit market is a trading venue providing mandatory pre-trade transparency. </a><a href="https://prime.greeks.live/area/order-management-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Order Management System

Meaning ▴ A robust Order Management System is a specialized software application engineered to oversee the complete lifecycle of financial orders, from their initial generation and routing to execution and post-trade allocation. </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">
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## 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/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A complex, layered mechanical system featuring interconnected discs and a central glowing core. This visualizes an institutional Digital Asset Derivatives Prime RFQ, facilitating RFQ protocols for price discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-prime-os-market-microstructure.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>

**Tags:** [Execution Venue Analysis](https://options.greeks.live/area/execution-venue-analysis/), [Pre-Trade Transparency](https://options.greeks.live/area/pre-trade-transparency/), [Transaction Cost Analysis](https://options.greeks.live/area/transaction-cost-analysis/), [International Capital Market Association](https://options.greeks.live/area/international-capital-market-association/), [Best Execution](https://options.greeks.live/area/best-execution/), [RTS 27](https://options.greeks.live/area/rts-27/)	

## Discover More

- 
### [How Does MiFID II Differ from FINRA Rules on Best Execution?](https://options.greeks.live/question/how-does-mifid-ii-differ-from-finra-rules-on-best-execution/)
![An abstract composition of interlocking, precisely engineered metallic plates represents a sophisticated institutional trading infrastructure. Visible perforations within a central block symbolize optimized data conduits for high-fidelity execution and capital efficiency. This visual metaphor highlights seamless interoperability, robust Prime RFQ architecture, and intelligent routing for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-multi-leg-execution-layer.jpg)

MiFID II mandates a quantitative, data-driven proof of best execution, while FINRA requires a documented, principles-based process.

- 
### [How Does Technology Influence a Firm’s Ability to Meet MiFID II Best Execution Standards?](https://options.greeks.live/question/how-does-technology-influence-a-firms-ability-to-meet-mifid-ii-best-execution-standards/)
![Translucent teal glass pyramid and flat pane, geometrically aligned on a dark base, symbolize market microstructure and price discovery within RFQ protocols for institutional digital asset derivatives. This visualizes multi-leg spread construction, high-fidelity execution via a Principal's operational framework, ensuring atomic settlement for latent liquidity.](https://options.greeks.live/wp-content/uploads/2025/07/transparent-geometric-structures-visualizing-multi-leg-spread-rfq-protocols-for-high-fidelity-institutional-digital-asset-derivatives-execution.jpg)

Technology provides the data architecture to transform MiFID II best execution from a qualitative duty into a quantitative, evidence-based discipline.

- 
### [How Should a Firm Operationally Manage Both MiFID II and FINRA Best Execution Obligations?](https://options.greeks.live/question/how-should-a-firm-operationally-manage-both-mifid-ii-and-finra-best-execution-obligations/)
![Symmetrical, institutional-grade Prime RFQ component for digital asset derivatives. Metallic segments signify interconnected liquidity pools and precise price discovery. A central intelligence layer drives high-fidelity execution via RFQ protocols, optimizing multi-leg spread transactions.](https://options.greeks.live/wp-content/uploads/2025/07/principals-prime-os-for-digital-asset-derivatives-rfq-execution.jpg)

A firm must architect a unified, data-driven execution system that treats dual compliance as a single operational discipline.

- 
### [How Does MiFID II Define the “All Sufficient Steps” Mandate?](https://options.greeks.live/question/how-does-mifid-ii-define-the-all-sufficient-steps-mandate/)
![An abstract composition featuring two overlapping digital asset liquidity pools, intersected by angular structures representing multi-leg RFQ protocols. This visualizes dynamic price discovery, high-fidelity execution, and aggregated liquidity within institutional-grade crypto derivatives OS, optimizing capital efficiency and mitigating counterparty risk.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-optimizing-aggregated-liquidity-and-multi-leg-execution-via-advanced-market-microstructure.jpg)

MiFID II's "all sufficient steps" mandate requires firms to build a provable, data-driven system for continuously optimizing client execution outcomes.

- 
### [What Are the Key Components of a MiFID II Compliant Best Execution Policy Now?](https://options.greeks.live/question/what-are-the-key-components-of-a-mifid-ii-compliant-best-execution-policy-now/)
![A multi-faceted algorithmic execution engine, reflective with teal components, navigates a cratered market microstructure. It embodies a Principal's operational framework for high-fidelity execution of digital asset derivatives, optimizing capital efficiency, best execution via RFQ protocols in a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/advanced-rfq-protocol-engine-for-institutional-digital-asset-derivatives.jpg)

A MiFID II Best Execution Policy is a firm's operational system for delivering and proving superior, client-centric execution outcomes.

- 
### [How Does the Systematic Internaliser Regime Impact a Firm’s Best Execution Obligations?](https://options.greeks.live/question/how-does-the-systematic-internaliser-regime-impact-a-firms-best-execution-obligations/)
![A dynamic visual representation of an institutional trading system, featuring a central liquidity aggregation engine emitting a controlled order flow through dedicated market infrastructure. This illustrates high-fidelity execution of digital asset derivatives, optimizing price discovery within a private quotation environment for block trades, ensuring capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/principal-os-driving-high-fidelity-execution-for-digital-asset-derivatives-through-optimized-rfq-protocols-and-smart-order-routing.jpg)

The SI regime integrates principal liquidity into the market, demanding a firm's execution system to quantitatively prove its routing decisions are optimal.

- 
### [How Does Deferred Reporting Impact a Firm’s Best Execution Obligations under MiFID II?](https://options.greeks.live/question/how-does-deferred-reporting-impact-a-firms-best-execution-obligations-under-mifid-ii/)
![A modular system with beige and mint green components connected by a central blue cross-shaped element, illustrating an institutional-grade RFQ execution engine. This sophisticated architecture facilitates high-fidelity execution, enabling efficient price discovery for multi-leg spreads and optimizing capital efficiency within a Prime RFQ framework for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/principal-prime-os-rfq-engine-for-digital-asset-derivatives.jpg)

Deferred reporting impacts best execution by shifting the burden of proof from public post-trade data to a firm's internal, auditable, pre-trade analysis.

- 
### [What Are the Key Differences in Best Execution Obligations When Using an SI versus an MTF?](https://options.greeks.live/question/what-are-the-key-differences-in-best-execution-obligations-when-using-an-si-versus-an-mtf/)
![Symmetrical precision modules around a central hub represent a Principal-led RFQ protocol for institutional digital asset derivatives. This visualizes high-fidelity execution, price discovery, and block trade aggregation within a robust market microstructure, ensuring atomic settlement and capital efficiency via a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/principal-led-digital-asset-rfq-execution-system-microstructure.jpg)

Best execution obligations diverge: SIs offer principal-based certainty, while MTFs provide multilateral price discovery.

- 
### [How Does an Sor Prove It Has Achieved Best Execution under Mifid Ii?](https://options.greeks.live/question/how-does-an-sor-prove-it-has-achieved-best-execution-under-mifid-ii/)
![The image features layered structural elements, representing diverse liquidity pools and market segments within a Principal's operational framework. A sharp, reflective plane intersects, symbolizing high-fidelity execution and price discovery via private quotation protocols for institutional digital asset derivatives, emphasizing atomic settlement nodes.](https://options.greeks.live/wp-content/uploads/2025/07/systemic-interplay-for-institutional-digital-asset-derivatives-execution-via-advanced-rfq-protocols.jpg)

An SOR proves best execution under MiFID II by generating an immutable audit trail that substantiates its routing decisions with quantitative TCA.

---

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                "text": "The mandate for SIs to publish pre-trade quotes for liquid instruments underpins the entire strategic shift. This data cannot remain passive. It must be actively integrated into the firm's Smart Order Router (SOR) logic. Imagine the SOR as a GPS for your orders. Previously, it navigated a map of public highways (exchanges, MTFs). Now, it must also see a network of private, high-speed toll roads (SIs)."
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                "text": "The integration of Systematic Internalisers into the European market structure was an architectural intervention designed to illuminate the OTC space. It forces a critical question upon every investment firm: is your current operational framework designed to look through this new window, or does it treat it as a wall? A legacy system, calibrated only for public exchange data, cannot perceive the liquidity and pricing information that now exists beyond its narrow view. Achieving a superior execution outcome in the current market is a function of observational capacity. The challenge is to ensure your firm's technological and analytical architecture provides a complete, panoramic view of all available liquidity, enabling your execution strategy to be truly systematic and demonstrably optimal."
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---

**Original URL:** https://options.greeks.live/question/how-do-sis-alter-the-calculation-of-best-execution-under-mifid-ii/
