# How Has the Phasing out of RTS 27 and RTS 28 Reports Changed the Strategic Approach to EU Best Execution? ▴ Question

**Published:** 2025-08-06
**Categories:** Question

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## Concept

The operational demand for absolute proof of best execution has fundamentally reshaped its own definition. The initial MiFID II framework introduced Regulatory Technical Standard (RTS) 27 and 28 reports as a structural answer to a systemic question of transparency. RTS 27 required [execution venues](https://prime.greeks.live/area/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to publish vast quarterly datasets on [execution quality](https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), detailing price, cost, and speed for every financial instrument. Concurrently, RTS 28 mandated that investment firms annually disclose their top five execution venues for each asset class, alongside a qualitative assessment of the execution quality achieved.

The system was architected as a feedback loop, where venue performance data was meant to inform and discipline firm routing decisions, theoretically creating a data-driven meritocracy of execution. This mechanism was a direct attempt to translate the abstract principle of “[best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)” into a tangible, comparable, and machine-readable format.

This data-centric system, however, produced an unintended consequence a deluge of information that was difficult to translate into actionable intelligence. The sheer volume and complexity of [RTS 27](https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) reports made meaningful comparison between venues a resource-intensive task, even for sophisticated institutions. Feedback from across the industry indicated the reports were rarely used by the investors they were intended to protect. This led regulators to a critical realization the architectural solution, while sound in principle, was misaligned with the operational realities of investment management.

The cost of producing and consuming this data began to outweigh its perceived utility, prompting a systemic re-evaluation. The phasing out of these reports is a direct acknowledgment of this imbalance. It signals a move away from a prescriptive, evidence-by-volume approach toward a regime that places greater emphasis on the firm’s internal [governance](https://prime.greeks.live/area/governance/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and qualitative judgment, backed by more targeted, relevant data analysis. The core obligation to achieve best execution remains unchanged; what has been redesigned is the framework for demonstrating compliance.

> The removal of RTS 27 and 28 reports marks a deliberate regulatory shift from a prescriptive, data-heavy compliance model to a principles-based framework for best execution.

This transition represents a maturation of the regulatory philosophy. The initial framework was built on the premise that mandated transparency would automatically lead to better outcomes. The revised approach recognizes that true best execution is a dynamic process, unique to each firm’s order flow and strategic intent. It cannot be fully captured by standardized quarterly reports.

The system now trusts firms to build and maintain their own robust monitoring frameworks, using tools like [Transaction Cost Analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA) not just as a reporting mechanism, but as an integrated part of the execution workflow. The focus shifts from public data disclosure to the internal logic and demonstrable rigor of a firm’s execution policy and governance structure. This places a greater burden on firms to understand and articulate their own execution strategies, moving the point of accountability from the public square of standardized reports to the internal forum of the [best execution committee](https://prime.greeks.live/area/best-execution-committee/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and the client review process.

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![An exposed institutional digital asset derivatives engine reveals its market microstructure. The polished disc represents a liquidity pool for price discovery](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-digital-asset-derivatives-rfq-execution-system.jpg)

## Strategy

The dismantling of the RTS 27 and 28 reporting architecture necessitates a profound strategic realignment for investment firms. The previous regime, with its focus on standardized, public disclosures, inadvertently fostered a “compliance-first” mindset. The primary strategic goal was often the timely and accurate production of reports.

The new environment demands a “client-first” execution philosophy, where the internal processes for achieving and evidencing best execution become the central focus. This is a move from a defensive posture of [regulatory reporting](https://prime.greeks.live/area/regulatory-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to a proactive stance of execution optimization and governance.

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## From Tick-Box Reporting to Holistic Governance

The core of the strategic change lies in elevating the best execution process from a compliance function to a core component of the investment value proposition. Without the prescriptive templates of RTS 27 and 28, firms must now design and implement their own comprehensive frameworks to satisfy the overarching [MiFID II](https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) requirement to take all “sufficient steps” to obtain the best possible result for their clients. This requires a qualitative and quantitative approach that is deeply integrated into the firm’s operational DNA.

The strategic imperatives now include:

- **Enhanced Internal Monitoring** ▴ Firms must develop more sophisticated and customized internal systems for monitoring execution quality. This involves moving beyond the basic metrics of price and cost to incorporate a wider range of factors, including likelihood of execution, settlement finality, and the implicit costs associated with information leakage and market impact.

- **Dynamic [Venue Analysis](https://prime.greeks.live/area/venue-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)** ▴ The static, annual disclosure of the top five venues under [RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is replaced by a need for continuous, dynamic analysis of all available execution venues. Firms must be able to justify their venue selection for specific trades and strategies based on real-time data and a documented, systematic process of evaluation.

- **Strengthened Governance** ▴ The role of the best execution committee or equivalent governing body becomes paramount. These bodies must now take a more active role in defining, overseeing, and documenting the firm’s execution policies and procedures. Their minutes and records become a primary source of evidence for regulatory scrutiny.

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## What Is the New Evidentiary Burden on Firms?

With the public reports gone, the evidentiary burden shifts inward. Regulators will now focus on the quality and robustness of a firm’s internal arrangements. The strategic challenge is to create a demonstrable and auditable trail that proves the firm is systematically working to achieve the best outcomes for its clients.

This involves a much deeper integration of [Transaction Cost](https://prime.greeks.live/area/transaction-cost/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Analysis (TCA) into the daily workflow. TCA evolves from a post-trade reporting tool into a pre-trade decision support system and a real-time monitoring utility.

> Firms must now architect an internal system of record that proves their commitment to best execution principles through process and governance, not just data reporting.

The table below outlines the strategic shift in focus for best execution frameworks, moving from the old regime to the new, principles-based environment.

| Execution Pillar | Previous Strategic Focus (RTS 27/28 Era) | Current Strategic Focus (Post-Reporting Era) |
| --- | --- | --- |
| Data & Analytics | Production and consumption of standardized RTS 27 data. Post-trade analysis for RTS 28 reporting. | Development of customized, internal TCA models. Integration of pre-trade, real-time, and post-trade analytics. |
| Venue Selection | Annual disclosure and summary justification of top five venues. | Dynamic, trade-by-trade justification of venue choice. Continuous monitoring of all potential liquidity sources. |
| Governance | Oversight of report production and accuracy. Annual review of execution policy. | Active, continuous oversight of the entire execution process. Detailed record-keeping of decisions and reviews. |
| Client Reporting | Providing clients with access to public RTS 28 reports. | Delivering tailored, meaningful execution quality analysis to clients upon request, demonstrating adherence to the firm’s policy. |
| Regulatory Proof | Demonstrating compliance through timely submission of public reports. | Demonstrating compliance through a robust, documented internal framework and governance structure. |

This evolution requires investment in both technology and human capital. Analytical systems must be capable of capturing and analyzing a more diverse set of data points, while staff must possess the expertise to interpret this data and make nuanced execution decisions. The strategy is one of deep internal capability building, creating a durable, defensible [execution framework](https://prime.greeks.live/area/execution-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) that stands up to regulatory inspection and, more importantly, consistently delivers value to clients.

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## Execution

In the absence of prescriptive reporting mandates, the execution of a best [execution policy](https://prime.greeks.live/area/execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) becomes an exercise in building a robust, internal system of control and analysis. The focus moves from generating public-facing reports to embedding a dynamic, data-driven process of continuous improvement and verification. This requires a granular approach to data management, a disciplined governance structure, and the right technological architecture to connect them.

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## Architecting the Modern Best Execution Framework

A firm’s execution framework must now operate as a self-contained ecosystem, capable of ingesting market data, processing internal order flow, analyzing execution outcomes, and generating insights for the governance body. This is a significant operational lift, requiring the integration of Order Management Systems (OMS), Execution Management Systems (EMS), and advanced TCA platforms.

The operational playbook involves several distinct steps:

- **Policy Codification** ▴ The firm’s Best Execution Policy must be translated into a set of quantifiable rules and parameters within the trading systems. This involves defining specific routing logic, setting tolerance levels for slippage against benchmarks, and establishing criteria for when manual intervention by a trader is required.

- **Data Capture at Point of Execution** ▴ Systems must be configured to capture a rich set of data for every single order. This goes far beyond the basic requirements of the old RTS reports. The goal is to build a complete “biography” of each order, from inception to settlement.

- **Integrated TCA Workflow** ▴ Transaction [Cost Analysis](https://prime.greeks.live/area/cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) must be woven into the entire trade lifecycle. Pre-trade TCA provides an estimate of expected costs, which serves as a benchmark. Real-time TCA monitors the order’s progress against that benchmark, flagging deviations. Post-trade TCA provides the final accounting and feeds data back into the system to refine future pre-trade models.

- **Systematic Governance Review** ▴ The Best Execution Committee must have access to a sophisticated dashboard that aggregates and visualizes execution data. Their review process must be systematic, data-driven, and meticulously documented.

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## How Should Firms Redefine Their Data Monitoring?

The key to successful execution in this new regime is monitoring the right data. The generic, one-size-fits-all nature of RTS 27 is replaced by a need for customized data dashboards that reflect the firm’s specific business model and client base. The following table provides an example of the granular data points a firm should now be monitoring internally, categorized by execution factor.

| Execution Factor | Key Data Point | Operational Purpose | System of Record |
| --- | --- | --- | --- |
| Price | Arrival Price vs. Execution Price | Measures price improvement or slippage against the market state at the time of order receipt. | OMS/TCA Platform |
| Costs | Explicit Costs (Fees, Commissions, Taxes) | Quantifies the direct, observable costs of trading. | OMS/Accounting System |
| Costs | Implicit Costs (Market Impact, Delay Cost) | Models the hidden costs of execution, such as price movement caused by the order itself. | TCA Platform |
| Speed | Order Placement to Execution Latency | Measures the efficiency of the execution pathway for latency-sensitive orders. | EMS/TCA Platform |
| Likelihood of Execution | Fill Rate Analysis (Full vs. Partial Fills) | Assesses the reliability of a venue or algorithm in completing orders. | OMS/TCA Platform |
| Size | Execution Size vs. Marketable Size | Analyzes performance on large-in-scale orders and the ability to source liquidity without signaling risk. | TCA Platform |
| Settlement | Settlement Failure Rates by Venue/Counterparty | Monitors the post-trade operational risk associated with different execution pathways. | Settlements System |

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## The Governance Cadence

The Best Execution Committee’s work becomes a continuous cycle of review and refinement. A quarterly review cycle is a common and robust approach. A typical agenda for such a meeting would involve a systematic review of the data captured above.

- **Review of Execution Analytics** ▴ A deep dive into the TCA reports for the preceding quarter. This involves analyzing performance by asset class, order type, venue, and even individual trader or portfolio manager. Any outliers or trends must be investigated and explained.

- **Venue and Broker Performance Review** ▴ A formal assessment of the execution quality provided by all brokers and venues used by the firm. This review must be based on the firm’s internal data, not the brokers’ own marketing materials. Underperforming venues or brokers should be placed on a watchlist or removed from the approved list.

- **Policy and Procedure Validation** ▴ An assessment of whether the firm’s execution policy remains appropriate given the prevailing market conditions and the firm’s business activities. Any proposed changes to routing logic or risk parameters must be debated, approved, and documented.

- **Documentation and Record-Keeping** ▴ The minutes of these meetings are a critical piece of regulatory evidence. They must clearly document the data that was reviewed, the decisions that were made, and the rationale behind those decisions.

This operational structure transforms best execution from a passive reporting requirement into an active, strategic function. It creates a closed-loop system where data informs policy, policy guides execution, and execution generates new data. This is the architecture of a modern, defensible, and ultimately more effective best execution framework.

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## References

- 1. European Securities and Markets Authority. (2024, February 13). ESMA public statement on reporting requirements under RTS 28. ESMA.

- 2. European Securities and Markets Authority. (2022, December 14). ESMA advises on deprioritisation of supervisory actions on the obligation to publish RTS 27 reports. ESMA.

- 3. Financial Conduct Authority. (2021, June). Markets Policy Newsletter. FCA.

- 4. Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU (MiFID II).

- 5. Commission Delegated Regulation (EU) 2017/576 of 8 June 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council with regard to regulatory technical standards for the annual publication by investment firms of information on the identity of execution venues and on the quality of execution (RTS 28).

- 6. Gomber, P. Haferkorn, M. & Wranik, P. (2017). MiFID II/MiFIR ▴ A new regulatory framework for European financial markets. In Shaping the future of finance (pp. 1-32). Springer, Cham.

- 7. Korczak, A. & Bohl, M. T. (2019). Best execution under MiFID II ▴ A plain field for competition?. Journal of Banking & Finance, 107, 105612.

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## Reflection

The retirement of the RTS 27 and 28 reporting framework clears the field, returning the locus of control for best execution squarely to the firm. The architecture of compliance is no longer a public utility constructed from standardized parts; it is now a bespoke system that must be designed, built, and maintained internally. This presents a fundamental question for every institution ▴ Is your operational framework merely a defensive measure designed to satisfy auditors, or is it an offensive weapon engineered to generate alpha?

The data, processes, and governance you assemble are the components of your firm’s execution intelligence. The quality of that intelligence will directly determine your capacity to navigate liquidity, manage risk, and deliver on client mandates. The regulatory shift compels a deeper form of introspection.

It asks you to look past the mechanics of compliance and examine the core philosophy that drives your interaction with the market. The system you build is a direct reflection of that philosophy.

![Symmetrical internal components, light green and white, converge at central blue nodes. This abstract representation embodies a Principal's operational framework, enabling high-fidelity execution of institutional digital asset derivatives via advanced RFQ protocols, optimizing market microstructure for price discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-core.jpg)

## Glossary

<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-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An intricate, transparent cylindrical system depicts a sophisticated RFQ protocol for digital asset derivatives. Internal glowing elements signify high-fidelity execution and algorithmic trading](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-protocol-architecture.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/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek pen hovers over a luminous circular structure with teal internal components, symbolizing precise RFQ initiation. This represents high-fidelity execution for institutional digital asset derivatives, optimizing market microstructure and achieving atomic settlement within a Prime RFQ liquidity pool](https://options.greeks.live/wp-content/uploads/2025/07/optimizing-digital-asset-derivatives-rfq-through-prime-os-precision.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/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Intersecting metallic components symbolize an institutional RFQ Protocol framework. This system enables High-Fidelity Execution and Atomic Settlement for Digital Asset Derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-system-specialists.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/governance/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered institutional digital asset derivatives execution system cutaway. The teal Prime RFQ casing reveals intricate market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-rfq-protocol-core-engine.jpg)

## Governance

Meaning ▴ Governance defines the structured framework of rules, processes, and controls applied to manage and direct an entity or system. </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">
![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)

## 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/best-execution-committee/?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)

## 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/regulatory-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated, multi-component system propels a sleek, teal-colored digital asset derivative trade. The complex internal structure represents a proprietary RFQ protocol engine with liquidity aggregation and price discovery mechanisms](https://options.greeks.live/wp-content/uploads/2025/07/principals-high-fidelity-rfq-engine-for-digital-asset-derivatives-execution.jpg)

## Regulatory Reporting

Meaning ▴ Regulatory Reporting refers to the systematic collection, processing, and submission of transactional and operational data by financial institutions to regulatory bodies in accordance with specific legal and jurisdictional mandates. </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 depiction of an institutional digital asset derivatives execution system. A central market microstructure wheel supports a Prime RFQ framework, revealing an algorithmic trading engine for high-fidelity execution of multi-leg spreads and block trades via advanced RFQ protocols, optimizing capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-rfq-execution-system-1.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/area/venue-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract spheres and a translucent flow visualize institutional digital asset derivatives market microstructure. It depicts robust RFQ protocol execution, high-fidelity data flow, and seamless liquidity aggregation](https://options.greeks.live/wp-content/uploads/2025/07/precision-market-microstructure-for-institutional-digital-asset-derivatives-leveraging-rfq-protocols-and-atomic-settlement-across-prime-os.jpg)

## Venue Analysis

Meaning ▴ Venue Analysis constitutes the systematic, quantitative assessment of diverse execution venues, including regulated exchanges, alternative trading systems, and over-the-counter desks, to determine their suitability for specific order flow. </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 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)

## 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/transaction-cost/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek conduit, embodying an RFQ protocol and smart order routing, connects two distinct, semi-spherical liquidity pools. Its transparent core signifies an intelligence layer for algorithmic trading and high-fidelity execution of digital asset derivatives, ensuring atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-execution-engine-bridging-diverse-liquidity-pools-via-high-fidelity-rfq-protocol-orchestration.jpg)

## Transaction Cost

Meaning ▴ Transaction Cost represents the total quantifiable economic friction incurred during the execution of a trade, encompassing both explicit costs such as commissions, exchange fees, and clearing charges, alongside implicit costs like market impact, slippage, and opportunity cost. </a><a href="https://prime.greeks.live/area/execution-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A modular, dark-toned system with light structural components and a bright turquoise indicator, representing a sophisticated Crypto Derivatives OS for institutional-grade RFQ protocols. It signifies private quotation channels for block trades, enabling high-fidelity execution and price discovery through aggregated inquiry, minimizing slippage and information leakage within dark liquidity pools](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-system-for-optimal-execution-1.jpg)

## Execution Framework

Meaning ▴ An Execution Framework represents a comprehensive, programmatic system designed to facilitate the systematic processing and routing of trading orders across various market venues, optimizing for predefined objectives such as price, speed, or minimized market impact. </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">
![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)

## 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/cost-analysis/?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)

## 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:** [Compliance Framework](https://options.greeks.live/area/compliance-framework/), [RTS 28](https://options.greeks.live/area/rts-28/), [RTS 27](https://options.greeks.live/area/rts-27/), [Execution Quality](https://options.greeks.live/area/execution-quality/), [Execution Venues](https://options.greeks.live/area/execution-venues/), [Transaction Cost Analysis](https://options.greeks.live/area/transaction-cost-analysis/)	

## Discover More

- 
### [How Do Firms Document Their Compliance with Best Execution Obligations?](https://options.greeks.live/question/how-do-firms-document-their-compliance-with-best-execution-obligations/)
![A sophisticated dark-hued institutional-grade digital asset derivatives platform interface, featuring a glowing aperture symbolizing active RFQ price discovery and high-fidelity execution. The integrated intelligence layer facilitates atomic settlement and multi-leg spread processing, optimizing market microstructure for prime brokerage operations and capital efficiency. This represents a robust crypto derivatives OS.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-rfq-engine-intelligence-layer.jpg)

Firms document best execution compliance by creating a verifiable audit trail of policies, governance, and data-driven analysis.

- 
### [What Are the Key Differences between the Us and Eu Best Execution Regimes?](https://options.greeks.live/question/what-are-the-key-differences-between-the-us-and-eu-best-execution-regimes/)
![A cutaway view reveals an advanced RFQ protocol engine for institutional digital asset derivatives. Intricate coiled components represent algorithmic liquidity provision and portfolio margin calculations. Translucent sections expose the quantitative analytics core enabling high-fidelity execution and low-latency order routing for Bitcoin options.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-engine-digital-asset-derivatives-core-internal-mechanism-visualized.jpg)

The core difference is the US's prescriptive, data-driven focus on routing conflicts versus the EU's principles-based, holistic duty of care.

- 
### [How Does MiFID II Define Best Execution Differently from FINRA?](https://options.greeks.live/question/how-does-mifid-ii-define-best-execution-differently-from-finra/)
![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)

MiFID II mandates a provable, data-centric system of "all sufficient steps," while FINRA requires a principles-based "reasonable diligence."

- 
### [How Do Regulatory Frameworks like MiFID II Influence the Measurement and Reporting of Information Leakage?](https://options.greeks.live/question/how-do-regulatory-frameworks-like-mifid-ii-influence-the-measurement-and-reporting-of-information-leakage/)
![A multi-faceted geometric object with varied reflective surfaces rests on a dark, curved base. It embodies complex RFQ protocols and deep liquidity pool dynamics, representing advanced market microstructure for precise price discovery and high-fidelity execution of institutional digital asset derivatives, optimizing capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/multi-faceted-institutional-digital-asset-derivatives-execution-infrastructure.jpg)

MiFID II mandates a systemic architecture of control, transforming information leakage from an accepted friction into a quantifiable compliance metric.

- 
### [How Did MiFID II Change the Definition of Best Execution for Firms?](https://options.greeks.live/question/how-did-mifid-ii-change-the-definition-of-best-execution-for-firms/)
![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)

MiFID II transformed best execution from a price-focused goal into a continuous, data-driven process of optimizing total client outcome.

- 
### [What Are the Core Components of a Legally Defensible Best Execution Policy under MiFID II?](https://options.greeks.live/question/what-are-the-core-components-of-a-legally-defensible-best-execution-policy-under-mifid-ii/)
![A precision mechanical assembly: black base, intricate metallic components, luminous mint-green ring with dark spherical core. This embodies an institutional Crypto Derivatives OS, its market microstructure enabling high-fidelity execution via RFQ protocols for intelligent liquidity aggregation and optimal price discovery.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-crypto-derivatives-rfq-engine-high-fidelity-execution.jpg)

A defensible MiFID II policy is a data-driven system proving all sufficient steps were taken to secure the best client outcome.

- 
### [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 Does the Choice of Venue Impact Best Execution Documentation for Electronic Orders?](https://options.greeks.live/question/how-does-the-choice-of-venue-impact-best-execution-documentation-for-electronic-orders/)
![An abstract, symmetrical four-pointed design embodies a Principal's advanced Crypto Derivatives OS. Its intricate core signifies the Intelligence Layer, enabling high-fidelity execution and precise price discovery across diverse liquidity pools. Radiating arms depict optimized RFQ protocols for multi-leg spread strategies, minimizing slippage.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine.jpg)

Venue choice dictates the data available to construct the best execution file, transforming a compliance duty into a strategic data asset.

- 
### [What Are the Key Differences in Best Execution Requirements between the EU and the US?](https://options.greeks.live/question/what-are-the-key-differences-in-best-execution-requirements-between-the-eu-and-the-us/)
![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)

EU's MiFID II mandates prescriptive, data-driven proof of best execution, while the US system requires a principles-based, diligent review.

---

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---

**Original URL:** https://options.greeks.live/question/how-has-the-phasing-out-of-rts-27-and-rts-28-reports-changed-the-strategic-approach-to-eu-best-execution/
