# How Does the Removal of RTS 28 Affect a Firm's Internal Governance? ▴ Question

**Published:** 2025-08-02
**Categories:** Question

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## Concept

The operational calculus of a financial firm’s governance is a system of inputs, processes, and verifiable outputs. The removal of the Regulatory Technical Standard 28, commonly known as RTS 28, represents a fundamental alteration of one of these systemic inputs. It is not a simple subtraction of a compliance task. Instead, it constitutes a powerful shift in the very architecture of accountability for [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

The mandate to publish annual reports detailing the top five [execution venues](https://prime.greeks.live/area/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) was intended as a public-facing mechanism for transparency. The underlying logic was that market forces, guided by this transparency, would compel firms toward optimal execution outcomes for their clients. This mechanism, however, proved to be a flawed component in the system. The reports were resource-intensive to produce and, as regulatory bodies and market participants alike concluded, seldom used for meaningful comparison.

Therefore, its removal is not a signal of deregulation. It is the deliberate replacement of an ineffective, external-facing control with an intensified expectation of a robust, internal, and dynamic [governance framework](https://prime.greeks.live/area/governance-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). The core duty of best execution, a pillar of [MiFID II](https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), remains unaltered. What has changed is the method of verification.

The burden of proof has migrated from a static, annual public disclosure to a continuous, internal process of monitoring, analysis, and justification. This alters the internal power dynamics and resource allocation of every affected firm. The focus must pivot from demonstrating compliance through report publication to proving [execution quality](https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) through a rigorous, evidence-based internal audit trail. This is a far more demanding task, requiring a deeper integration of data analytics, risk management, and operational oversight into the fabric of the firm’s [governance structure](https://prime.greeks.live/question/what-are-the-governance-protocols-for-an-rfq-platform/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

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## The Systemic Function of RTS 28

To understand the impact of its removal, one must first model the intended function of RTS 28 within the broader MiFID II architecture. It was designed as a feedback loop. Firms execute orders, collect data on these executions, analyze the data, and then publicly report on their venue choices and the quality achieved.

This public report was meant to serve two primary audiences ▴ clients, who could theoretically use the data to assess their brokers, and the firms themselves, as a forcing function for self-assessment. The standard mandated a specific format for this disclosure, covering different classes of financial instruments and detailing metrics on price, costs, speed, and likelihood of execution.

The systemic flaw, however, was in the design of the feedback loop itself. The data, while voluminous, lacked the context necessary for true comparability. Different firms employed different methodologies for calculating execution quality, making a direct, apples-to-apples comparison between two RTS 28 reports a futile exercise. Furthermore, the sheer volume and complexity of the reports made them inaccessible to the very clients they were meant to empower.

Institutional clients already possessed far more sophisticated methods for evaluating execution quality, primarily through [Transaction Cost Analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA), rendering the RTS 28 reports largely redundant for their purposes. Consequently, the primary effect of RTS 28 was to create a significant compliance overhead without delivering a commensurate benefit in terms of market transparency or improved client outcomes.

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## Recalibrating the Governance Architecture

With the removal of this external reporting obligation, the system’s equilibrium shifts. The regulatory expectation does not vanish; it transforms. National Competent Authorities (NCAs) now expect firms to possess an [internal governance](https://prime.greeks.live/area/internal-governance/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) framework that can demonstrate, at any given moment, that best execution is being systematically achieved and monitored.

This requires a fundamental re-engineering of internal processes. The compliance function, which may have previously focused on the timely and accurate production of the RTS 28 report, must now pivot to a role of active surveillance and validation of the firm’s execution quality monitoring systems.

> The removal of RTS 28 reporting shifts the focus from public compliance to internal, evidence-based assurance of best execution.

This recalibration places a greater emphasis on the firm’s internal data infrastructure. Where data collection might have been geared towards populating the specific fields of an RTS 28 report, it must now be architected to support a dynamic, multi-faceted analysis of execution quality. This includes capturing a richer set of data points, such as order fill rates, [price improvement](https://prime.greeks.live/area/price-improvement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) statistics, and detailed breakdowns of implicit costs like [market impact](https://prime.greeks.live/area/market-impact/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). The governance structure must evolve to effectively utilize this data, establishing clear lines of responsibility for reviewing execution quality, challenging suboptimal outcomes, and documenting the rationale behind venue selection.

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## What Is the True Nature of Best Execution Post RTS 28?

Best execution, in the absence of RTS 28’s prescriptive reporting, returns to its core principles. It is the obligation for a firm to take all sufficient steps to obtain the best possible result for its clients, taking into account a range of execution factors. These factors include not only the explicit costs of execution but also price, speed, likelihood of execution and settlement, size, nature of the order, and any other consideration relevant to the execution of the order.

The removal of RTS 28 elevates the importance of the qualitative aspects of this obligation. A firm’s governance framework must now be able to articulate and defend its [execution policy](https://prime.greeks.live/area/execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), not just in terms of the quantitative data it produces, but also in terms of the strategic decisions it makes regarding venue selection and [order routing](https://prime.greeks.live/area/order-routing/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

This creates a more nuanced and demanding governance challenge. A firm must be able to demonstrate, for example, why it chooses to route certain orders to a dark pool, a systematic internaliser, or a lit market. This requires a deep understanding of [market microstructure](https://prime.greeks.live/area/market-microstructure/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and a sophisticated framework for assessing the trade-offs between different execution venues. The internal governance process must be able to document this decision-making process, creating an auditable trail that justifies the firm’s execution strategy in the context of its overarching duty to its clients.

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## Strategy

The strategic response to the obsolescence of RTS 28 reporting must be architected around a central principle ▴ the internalization of accountability. Firms that previously viewed best execution through the prism of an annual, public-facing compliance report must now construct a dynamic, internal system of control and continuous improvement. This is not a matter of simply reallocating the resources once dedicated to RTS 28 production.

It requires a strategic realignment of technology, human capital, and governance processes to create a framework that is demonstrably superior to the one it replaces. The objective is to build a system that provides regulators with confidence and clients with superior outcomes, all while enhancing the firm’s own understanding of its execution footprint.

A successful strategy involves a multi-pronged approach. It begins with a fundamental reassessment of the firm’s [best execution policy](https://prime.greeks.live/area/best-execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This policy can no longer be a static document that is reviewed annually. It must become a living framework that adapts to changing market conditions, new execution technologies, and the evolving needs of the firm’s clients.

The strategy must then translate this policy into a set of concrete operational processes, supported by a robust data and analytics infrastructure. Finally, the strategy must establish a clear and effective governance structure to oversee the entire process, ensuring that the firm is not only meeting its regulatory obligations but also continuously optimizing its execution performance.

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## Evolving the Best Execution Policy

The first step in this strategic realignment is to evolve the best execution policy from a compliance document into a strategic charter. This means moving beyond a simple recitation of the regulatory requirements and creating a document that clearly articulates the firm’s philosophy and approach to achieving best execution. The policy should detail the relative importance of the various execution factors for different types of clients and financial instruments. For example, for a large institutional client executing a block trade in an illiquid stock, the likelihood of execution and the minimization of market impact may be the most important factors, while for a retail client executing a small trade in a liquid stock, speed and explicit cost may be paramount.

The policy must also provide a detailed methodology for how the firm assesses the quality of its execution. This should include a description of the quantitative metrics the firm uses to monitor its performance, such as effective spread, price improvement, and slippage. It should also outline the qualitative factors the firm considers, such as the quality of a venue’s clearing and settlement processes or its resilience to market stress. This level of detail provides a clear framework for the firm’s internal monitoring processes and demonstrates to regulators that the firm has a sophisticated and well-considered approach to best execution.

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## From Static Reporting to Dynamic Monitoring

The core of the new strategy lies in the transition from static, backward-looking reporting to dynamic, real-time monitoring. This requires a significant investment in technology and [data analytics](https://prime.greeks.live/area/data-analytics/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). Firms must build or acquire systems that can capture and analyze execution data on a continuous basis, providing the front office and compliance functions with timely and actionable insights. These systems should be capable of generating a range of reports and dashboards that allow the firm to monitor its performance against its own internal benchmarks and against the broader market.

> A firm’s governance framework must be able to articulate and defend its execution policy, not just in terms of quantitative data, but also in terms of strategic decisions.

The table below illustrates the strategic shift in data and monitoring philosophy:

| Governance Aspect | RTS 28 Regime (Legacy Strategy) | Post-RTS 28 Regime (Modern Strategy) |
| --- | --- | --- |
| Primary Focus | Annual, public, template-based reporting. | Continuous, internal, exception-based monitoring. |
| Data Granularity | Aggregated data sufficient for RTS 28 fields. | Tick-level data, order lifecycle events, market impact metrics. |
| Analytical Approach | Backward-looking, descriptive statistics. | Real-time analytics, predictive modeling, peer-group benchmarking. |
| Audience | Public, regulators (theoretically). | Internal (Trading, Compliance, Senior Management), Regulators (on request). |
| Technology Stack | Data warehousing and report generation tools. | Real-time data capture, stream processing, advanced TCA engines. |

This shift requires a new set of capabilities. Firms need to develop expertise in areas such as data science and quantitative analysis to build and maintain these systems. They also need to foster a culture of data-driven decision-making, where the insights generated by these systems are used to inform trading strategies and improve client outcomes. The goal is to create a virtuous circle, where better data leads to better analysis, which in turn leads to better execution, further enriching the dataset.

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## Strengthening the Governance Framework

A sophisticated data and analytics infrastructure is necessary but not sufficient. It must be embedded within a strong governance framework that ensures the insights it generates are acted upon. This means establishing clear roles and responsibilities for overseeing best execution.

Many firms have established a Best Execution Committee, composed of senior representatives from the front office, compliance, risk, and technology. This committee should be responsible for reviewing the firm’s execution performance, approving changes to the best execution policy, and overseeing the firm’s relationships with its execution venues.

The governance framework must also include a clear process for escalating and resolving any issues that are identified through the firm’s monitoring processes. If the data reveals that a particular execution venue is consistently delivering poor outcomes, for example, there must be a process for investigating the issue, engaging with the venue to seek improvements, and, if necessary, removing the venue from the firm’s list of approved execution venues. This process should be fully documented, creating a clear audit trail that demonstrates the firm’s commitment to proactively managing its execution quality.

The following list outlines key components of a strengthened internal governance structure:

- **Best Execution Committee** ▴ A cross-functional body with ultimate responsibility for oversight. Its charter should define its membership, meeting frequency, and decision-making authority.

- **Documented Venue Selection Process** ▴ A formal methodology for adding, reviewing, and removing execution venues. This process should be based on a comprehensive assessment of each venue’s capabilities and performance.

- **Internal Audit Program** ▴ A dedicated audit function to periodically and independently test the effectiveness of the firm’s best execution monitoring and governance processes.

- **Training and Competence** ▴ A program to ensure that all relevant staff, from traders to compliance officers, understand their responsibilities under the firm’s best execution policy.

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## Execution

The execution phase of adapting to a post-RTS 28 environment is where strategic theory is forged into operational reality. It is about instrumenting the firm’s trading and compliance architecture to function as a self-auditing system. The objective is to create a demonstrable, evidence-based culture of best execution that permeates every level of the organization.

This requires a granular focus on the data, the analytical tools, and the procedural workflows that translate the firm’s best execution policy into a set of repeatable and verifiable actions. The successful execution of this strategy hinges on the ability to not only capture the right data but also to transform that data into actionable intelligence that drives continuous improvement.

This section provides a deep dive into the practical mechanics of building this internal governance framework. It will cover the specific data points that need to be captured, the analytical techniques that should be employed, and the design of the internal reporting and oversight processes. The focus here is on the tangible steps a firm must take to build a system that is not only compliant with the spirit of MiFID II but also provides a genuine competitive advantage through superior execution quality.

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## The Operational Playbook for Internal Monitoring

The cornerstone of the new execution framework is a detailed operational playbook that codifies the firm’s approach to best execution monitoring. This playbook should be a practical guide for everyone involved in the execution process, from the trader on the desk to the compliance officer in the back office. It should specify the exact procedures for monitoring execution quality, investigating potential issues, and documenting the firm’s decision-making process. The playbook is the blueprint for the firm’s internal control system.

A key element of this playbook is the definition of the firm’s internal “standard of care.” This is the benchmark against which all executions are measured. This standard should be multi-dimensional, incorporating not only the explicit costs of trading but also a range of implicit costs and qualitative factors. For example, the standard might specify acceptable thresholds for slippage against the arrival price, targets for price improvement, and minimum standards for the technological resilience of an execution venue. By defining this standard in detail, the firm creates a clear and objective basis for assessing its performance.

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## How Should a Firm Structure Its Internal Data Analysis?

The analysis of execution data must be both comprehensive and targeted. It is not enough to simply calculate a few high-level metrics. The firm must be able to drill down into the data to understand the drivers of its execution performance.

This requires a sophisticated analytical engine that can slice and dice the data by a variety of dimensions, including asset class, order type, client category, and execution venue. The goal is to identify patterns and anomalies that may indicate opportunities for improvement or potential areas of concern.

The table below provides a sample structure for an internal execution quality dashboard, highlighting the key metrics that a firm should be tracking.

| Metric Category | Key Performance Indicator (KPI) | Description | Target Audience |
| --- | --- | --- | --- |
| Price Improvement | Effective Spread Capture | Measures the portion of the bid-ask spread that the firm captures for its clients. | Trading Desk, Best ExCo |
| Slippage Analysis | Arrival Price Slippage | Measures the difference between the price at which an order was submitted and the price at which it was executed. | Trading Desk, Compliance |
| Venue Performance | Fill Rate by Venue | Measures the percentage of orders sent to a venue that are successfully executed. | Best ExCo, Venue Management |
| Latency | Order-to-Execution Latency | Measures the time taken from order submission to execution confirmation. | Technology, Trading Desk |
| Cost Analysis | Total Cost Analysis (TCA) | A comprehensive analysis of all explicit and implicit costs associated with an execution. | Senior Management, Clients |

This type of detailed analysis allows the firm to move beyond simple compliance and into the realm of active performance management. For example, by analyzing fill rates by venue, the firm can identify which venues are most effective for different types of orders and adjust its routing logic accordingly. By tracking slippage, the firm can identify traders or algorithms that may be creating undue market impact and provide them with additional training or guidance.

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## System Integration and Technological Architecture

The execution of this strategy is heavily dependent on the firm’s technological architecture. The various systems involved in the trading lifecycle, from the Order Management System (OMS) to the execution venues and the post-trade processing systems, must be tightly integrated to ensure a seamless flow of data. The firm’s data architecture must be designed to capture and store a rich set of time-stamped data for every order, including all order modifications, cancellations, and executions. This data is the raw material for the firm’s analytical engine.

> The successful execution of a post-RTS 28 strategy hinges on transforming captured data into actionable intelligence for continuous improvement.

A modern best execution framework requires a technology stack that can support real-time data ingestion, complex event processing, and advanced analytics. Many firms are turning to specialized third-party vendors for these capabilities, leveraging their expertise and economies of scale. Whether built in-house or sourced from a vendor, the system must be flexible and scalable enough to adapt to the firm’s evolving needs and the changing market environment. The ultimate goal is to create a single source of truth for all execution-related data, providing a comprehensive and auditable record of the firm’s trading activity.

The following list details the critical technological components required:

- **Centralized Data Hub** ▴ A repository for capturing and normalizing all order and execution data from various internal and external sources. This should include high-precision timestamping capabilities.

- **Transaction [Cost Analysis](https://prime.greeks.live/area/cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA) Engine** ▴ A sophisticated analytical tool for calculating a wide range of execution quality metrics and benchmarking performance against various reference points.

- **Rules-Based Alerting System** ▴ An automated system for flagging executions that breach predefined thresholds or deviate from expected patterns, allowing for real-time investigation.

- **Reporting and Visualization Layer** ▴ A flexible reporting tool that can generate a variety of dashboards and reports for different internal stakeholders, from the [trading desk](https://prime.greeks.live/area/trading-desk/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to the board room.

By investing in this technological foundation, a firm can transform the challenge of best execution from a regulatory burden into a source of competitive strength. It enables a proactive, data-driven approach to managing execution quality that not only satisfies regulators but also delivers tangible benefits to the firm and its clients.

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## References

- European Securities and Markets Authority. “ESMA clarifies certain best execution reporting requirements under MiFID II.” 13 February 2024.

- The TRADE. “ESMA officially scraps ‘hardly read’ RTS 28 best execution reports.” 13 February 2024.

- DLA Piper. “ESMA publishes statement on reporting requirements under RTS 28 of MiFID II.” 20 February 2024.

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

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## Reflection

The dismantling of the RTS 28 reporting framework should prompt a period of critical self-assessment within every investment firm. It compels a shift in perspective, moving the measure of diligence from the public performance of compliance to the private, rigorous cultivation of an evidence-based operational culture. The core question for any leadership team is no longer “Have we filed the correct report?” but rather “Can we prove, with high-fidelity data and a defensible methodology, that our execution framework consistently serves our clients’ best interests?”

This transition elevates the conversation beyond mere regulatory adherence. It forces an examination of the firm’s entire execution architecture ▴ its technology, its analytical capabilities, its governance structures, and, most importantly, its culture. Viewing best execution not as a constraint but as a domain for optimization is the hallmark of a sophisticated market participant. The data infrastructure built to satisfy this new paradigm of internal accountability becomes a strategic asset, offering insights that can enhance trading performance, manage risk more effectively, and ultimately, deepen client trust.

The removal of a flawed metric provides the opportunity to build a superior system of intelligence. The ultimate test is whether a firm seizes this opportunity to engineer a true operational edge.

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## 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">
![Abstract layers visualize institutional digital asset derivatives market microstructure. Teal dome signifies optimal price discovery, high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/08/high-fidelity-digital-asset-derivatives-rfq-execution-protocol-layers-and-market-microstructure-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/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A futuristic system component with a split design and intricate central element, embodying advanced RFQ protocols. This visualizes high-fidelity execution, precise price discovery, and granular market microstructure control for institutional digital asset derivatives, optimizing liquidity provision and minimizing slippage](https://options.greeks.live/wp-content/uploads/2025/07/advanced-rfq-protocols-for-digital-asset-derivatives-price-discovery.jpg)

## Execution Venues

Meaning ▴ Execution Venues are regulated marketplaces or bilateral platforms where financial instruments are traded and orders are matched, encompassing exchanges, multilateral trading facilities, organized trading facilities, and over-the-counter desks. </a><a href="https://prime.greeks.live/area/governance-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central processing core with intersecting, transparent structures revealing intricate internal components and blue data flows. This symbolizes an institutional digital asset derivatives platform's Prime RFQ, orchestrating high-fidelity execution, managing aggregated RFQ inquiries, and ensuring atomic settlement within dynamic market microstructure, optimizing capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-trading-system-facilitating-high-fidelity-rfq-protocol-optimization-for-best-execution-and-atomic-settlement.jpg)

## Governance Framework

Meaning ▴ A Governance Framework defines the structured system of policies, procedures, and controls established to direct and oversee operations within a complex institutional environment, particularly concerning digital asset derivatives. </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">
![A gleaming, translucent sphere with intricate internal mechanisms, flanked by precision metallic probes, symbolizes a sophisticated Principal's RFQ engine. This represents the atomic settlement of multi-leg spread strategies, enabling high-fidelity execution and robust price discovery within institutional digital asset derivatives markets, minimizing latency and slippage for optimal alpha generation and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/inst-digital-asset-deriv-rfq-os-for-optimal-high-fidelity-trade-exec.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/what-are-the-governance-protocols-for-an-rfq-platform/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Internal mechanism with translucent green guide, dark components. Represents Market Microstructure of Institutional Grade Crypto Derivatives OS](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-crypto-derivatives-rfq-engine-for-high-fidelity-execution.jpg)

## Governance Structure

RFQ governance protocols are the architectural framework for managing information leakage while optimizing price discovery in off-book liquidity sourcing. </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">
![Intersecting multi-asset liquidity channels with an embedded intelligence layer define this precision-engineered framework. It symbolizes advanced institutional digital asset RFQ protocols, visualizing sophisticated market microstructure for high-fidelity execution, mitigating counterparty risk and enabling atomic settlement across crypto derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-execution-system-microstructure-dynamics.jpg)

## 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/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A smooth, light-beige spherical module features a prominent black circular aperture with a vibrant blue internal glow. This represents a dedicated institutional grade sensor or intelligence layer for high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-intelligence-layer-for-optimal-digital-asset-rfq-execution.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/area/internal-governance/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Internal components of a Prime RFQ execution engine, with modular beige units, precise metallic mechanisms, and complex data wiring. This infrastructure supports high-fidelity execution for institutional digital asset derivatives, facilitating advanced RFQ protocols, optimal liquidity aggregation, multi-leg spread trading, and efficient price discovery](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-core-rfq-engine-for-institutional-digital-asset-options.jpg)

## Internal Governance

Meaning ▴ Internal Governance refers to the structured framework of policies, procedures, and technological controls within an institution that dictates the management of its digital asset operations, encompassing capital allocation, risk limits, trading authority, and operational workflows. </a><a href="https://prime.greeks.live/area/price-improvement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A robust, multi-layered institutional Prime RFQ, depicted by the sphere, extends a precise platform for private quotation of digital asset derivatives. A reflective sphere symbolizes high-fidelity execution of a block trade, driven by algorithmic trading for optimal liquidity aggregation within market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/robust-institutional-platform-for-digital-asset-derivatives-rfq-protocols-and-optimized-liquidity-aggregation.jpg)

## Price Improvement

Meaning ▴ Price improvement denotes the execution of a trade at a more advantageous price than the prevailing National Best Bid and Offer (NBBO) at the moment of order submission. </a><a href="https://prime.greeks.live/area/market-impact/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A robust circular Prime RFQ component with horizontal data channels, radiating a turquoise glow signifying price discovery. This institutional-grade RFQ system facilitates high-fidelity execution for digital asset derivatives, optimizing market microstructure and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-engine-for-digital-asset-derivatives-execution.jpg)

## Market Impact

Meaning ▴ Market Impact refers to the observed change in an asset's price resulting from the execution of a trading order, primarily influenced by the order's size relative to available liquidity and prevailing market conditions. </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">
![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)

## 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/order-routing/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered metallic and glass system depicts the core of an Institutional Grade Prime RFQ, facilitating high-fidelity execution for Digital Asset Derivatives. Transparent layers represent visible liquidity pools and the intricate market microstructure supporting RFQ protocol processing, ensuring atomic settlement capabilities](https://options.greeks.live/wp-content/uploads/2025/08/robust-institutional-digital-asset-derivatives-trading-platform-for-optimized-rfq-protocol-execution-and-deep-liquidity-access.jpg)

## Order Routing

Meaning ▴ Order Routing is the automated process by which a trading order is directed from its origination point to a specific execution venue or liquidity source. </a><a href="https://prime.greeks.live/area/market-microstructure/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A dual-toned cylindrical component features a central transparent aperture revealing intricate metallic wiring. This signifies a core RFQ processing unit for Digital Asset Derivatives, enabling rapid Price Discovery and High-Fidelity Execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-core-best-execution-prime-os.jpg)

## Market Microstructure

Meaning ▴ Market Microstructure refers to the study of the processes and rules by which securities are traded, focusing on the specific mechanisms of price discovery, order flow dynamics, and transaction costs within a trading 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">
![An abstract visual depicts a central intelligent execution hub, symbolizing the core of a Principal's operational framework. Two intersecting planes represent multi-leg spread strategies and cross-asset liquidity pools, enabling private quotation and aggregated inquiry for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-engine-for-institutional-digital-asset-derivatives.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/area/data-analytics/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Precision-engineered components of an institutional-grade system. The metallic teal housing and visible geared mechanism symbolize the core algorithmic execution engine for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-institutional-digital-asset-derivatives-rfq-execution-layer.jpg)

## Data Analytics

Meaning ▴ Data Analytics involves the systematic computational examination of large, complex datasets to extract patterns, correlations, and actionable insights. </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">
![Textured institutional-grade platform presents RFQ inquiry disk amidst liquidity fragmentation. Singular price discovery point floats](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-execution-microstructure-prime-os-best-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><a href="https://prime.greeks.live/area/trading-desk/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Two abstract, segmented forms intersect, representing dynamic RFQ protocol interactions and price discovery mechanisms. The layered structures symbolize liquidity aggregation across multi-leg spreads within complex market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-microstructure.jpg)

## Trading Desk

Meaning ▴ A Trading Desk represents a specialized operational system within an institutional financial entity, designed for the systematic execution, risk management, and strategic positioning of proprietary capital or client orders across various asset classes, with a particular focus on the complex and nascent digital asset derivatives landscape. </a>

**Tags:** [Price Improvement](https://options.greeks.live/area/price-improvement/), [Compliance Framework](https://options.greeks.live/area/compliance-framework/), [Order Routing](https://options.greeks.live/area/order-routing/), [MiFID II](https://options.greeks.live/area/mifid-ii/), [Financial Regulation](https://options.greeks.live/area/financial-regulation/), [Cost Analysis](https://options.greeks.live/area/cost-analysis/)	

## Discover More

- 
### [How Should an Institution’s Best Execution Policy Evolve with Changes in Market Structure?](https://options.greeks.live/question/how-should-an-institutions-best-execution-policy-evolve-with-changes-in-market-structure/)
![A polished, abstract geometric form represents a dynamic RFQ Protocol for institutional-grade digital asset derivatives. A central liquidity pool is surrounded by opening market segments, revealing an emerging arm displaying high-fidelity execution data. This signifies algorithmic trading for private quotation and efficient price discovery within market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-institutional-digital-asset-derivatives-rfq-protocol-system.jpg)

An institution's best execution policy must evolve from a static compliance document into a dynamic, data-driven system that adapts to market fragmentation.

- 
### [What Is the Precise Role and Responsibility of a Best Execution Committee under These Rules?](https://options.greeks.live/question/what-is-the-precise-role-and-responsibility-of-a-best-execution-committee-under-these-rules/)
![A sleek blue and white mechanism with a focused lens symbolizes Pre-Trade Analytics for Digital Asset Derivatives. A glowing turquoise sphere represents a Block Trade within a Liquidity Pool, demonstrating High-Fidelity Execution via RFQ protocol for Price Discovery in Dark Pool Market Microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/advanced-institutional-digital-asset-derivatives-rfq-execution-system-for-optimal-price-discovery-and-high-fidelity-execution.jpg)

The Best Execution Committee architects and governs the firm's trading nervous system to ensure optimal capital efficiency and risk management.

- 
### [How Do Firms Quantitatively Measure and Prove Best Execution to Regulators?](https://options.greeks.live/question/how-do-firms-quantitatively-measure-and-prove-best-execution-to-regulators/)
![A transparent teal prism on a white base supports a metallic pointer. This signifies an Intelligence Layer on Prime RFQ, enabling high-fidelity execution and algorithmic trading. It optimizes market microstructure for precise price discovery and capital efficiency via RFQ protocols.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-derivatives-rfq-execution-prime-microstructure-liquidity.jpg)

Firms prove best execution by systematically documenting a data-driven process that optimizes for price, cost, and speed using Transaction Cost Analysis.

- 
### [What Are the Core Components of a Defensible Best Execution Policy?](https://options.greeks.live/question/what-are-the-core-components-of-a-defensible-best-execution-policy/)
![A central glowing blue mechanism with a precision reticle is encased by dark metallic panels. This symbolizes an institutional-grade Principal's operational framework for high-fidelity execution of digital asset derivatives. It embodies RFQ processing, enabling price discovery within a deep liquidity pool, optimizing market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/precision-core-enabling-institutional-digital-asset-derivatives-rfq-execution.jpg)

A defensible best execution policy is a dynamic system codifying how a firm achieves and proves superior, data-driven trading outcomes.

- 
### [How Does the SI Model Affect Best Execution Obligations for the Buy-Side?](https://options.greeks.live/question/how-does-the-si-model-affect-best-execution-obligations-for-the-buy-side/)
![A diagonal composition contrasts a blue intelligence layer, symbolizing market microstructure and volatility surface, with a metallic, precision-engineered execution engine. This depicts high-fidelity execution for institutional digital asset derivatives via RFQ protocols, ensuring atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-for-institutional-digital-asset-derivatives-execution.jpg)

The Systematic Internaliser model compels buy-side firms to evolve best execution from a compliance task into a data-driven, strategic capability.

- 
### [How Does the Removal of Rts 28 Affect a Firm’s Evidentiary Burden for Best Execution?](https://options.greeks.live/question/how-does-the-removal-of-rts-28-affect-a-firms-evidentiary-burden-for-best-execution/)
![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)

The removal of RTS 28 elevates a firm's evidentiary burden from a reporting task to a systemic proof of best execution.

- 
### [How Do Systematic Internalisers Impact Best Execution Obligations in the European Union?](https://options.greeks.live/question/how-do-systematic-internalisers-impact-best-execution-obligations-in-the-european-union/)
![Precision-engineered system components in beige, teal, and metallic converge at a vibrant blue interface. This symbolizes a critical RFQ protocol junction within an institutional Prime RFQ, facilitating high-fidelity execution and atomic settlement for digital asset derivatives. It optimizes latency and market microstructure for private quotation and block trades.](https://options.greeks.live/wp-content/uploads/2025/07/principal-rfq-connectivity-layer-for-digital-asset-derivatives-execution.jpg)

Systematic Internalisers reshape EU best execution by offering a principal liquidity source that demands rigorous, data-driven venue analysis.

- 
### [What Are the Key Responsibilities of a Best Execution Committee in Practice?](https://options.greeks.live/question/what-are-the-key-responsibilities-of-a-best-execution-committee-in-practice/)
![A sleek, multi-component device with a dark blue base and beige bands culminates in a sophisticated top mechanism. This precision instrument symbolizes a Crypto Derivatives OS facilitating RFQ protocol for block trade execution, ensuring high-fidelity execution and atomic settlement for institutional-grade digital asset derivatives across diverse liquidity pools.](https://options.greeks.live/wp-content/uploads/2025/08/advanced-mechanism-for-principal-trading-firm-rfq-protocols-and-high-fidelity-digital-asset-derivatives-execution.jpg)

The Best Execution Committee operationalizes a firm's fiduciary duty, systematically translating policy into quantifiable execution quality.

- 
### [What Is the Role of a Best Execution Committee in the Governance Structure of an Investment Firm?](https://options.greeks.live/question/what-is-the-role-of-a-best-execution-committee-in-the-governance-structure-of-an-investment-firm/)
![Robust metallic beam depicts institutional digital asset derivatives execution platform. Two spherical RFQ protocol nodes, one engaged, one dislodged, symbolize high-fidelity execution, dynamic price discovery. Water droplets signify granular market microstructure, Prime RFQ liquidity.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-prime-os-node.jpg)

The Best Execution Committee is the central governance node for architecting and enforcing a data-driven execution policy.

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        "MiFID II",
        "Order Routing",
        "Price Improvement",
        "Regulatory Reporting",
        "Trading Desk",
        "Transaction Cost Analysis",
        "Venue Analysis"
    ]
}
```

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```


---

**Original URL:** https://options.greeks.live/question/how-does-the-removal-of-rts-28-affect-a-firms-internal-governance/
