# How Has the Suspension of RTS 27 and RTS 28 Reporting Affected SI Compliance and Monitoring Practices? ▴ Question

**Published:** 2025-08-17
**Categories:** Question

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## The Data Void and the New Compliance Calculus

The suspension of Regulatory Technical Standard (RTS) 27 and the subsequent removal of RTS 28 reporting obligations initiated a significant recalibration in the compliance and monitoring architecture for Systematic Internalisers (SIs). This was not a simple removal of a burdensome reporting task; it represented a fundamental shift in the data landscape that underpins [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) verification. For compliance departments, the predictable, albeit cumbersome, quarterly influx of [RTS 27](https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) data from execution venues ▴ detailing metrics on price, cost, and speed ▴ vanished.

This created an immediate data void, compelling a move away from a check-the-box reliance on standardized [public reports](https://prime.greeks.live/question/how-do-mifid-ii-reporting-timelines-differ-between-public-trade-reports-and-regulatory-transaction-reports/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) toward a more dynamic, internally-driven, and qualitative [monitoring framework](https://prime.greeks.live/question/how-does-the-monitoring-of-information-leakage-in-rfq-protocols-differ-from-monitoring-lit-market-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). The core challenge for SIs transformed overnight from data aggregation and reporting to data sourcing and interpretation in a less transparent market.

Systematic Internalisers, defined as investment firms dealing on their own account by executing client orders outside a regulated market or multilateral trading facility (MTF), were primary producers and consumers of this data. RTS 27 required them, as execution venues, to publish detailed quarterly reports on [execution quality](https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). Concurrently, [RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) mandated that investment firms publish an annual summary of the top five execution venues they used and a qualitative assessment of the execution quality achieved.

The initial suspension, driven by the COVID-19 pandemic and later solidified by regulators acknowledging the reports were rarely used and offered little comparative value, effectively removed a key public benchmark. This regulatory pivot forced SIs to re-evaluate the very foundation of how they evidence and monitor their adherence to the [MiFID II](https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) best execution mandate.

> The removal of RTS 27 and 28 obligations transitioned the focus of SI compliance from standardized public disclosure to the development of sophisticated, proprietary monitoring systems.

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## Redefining the Evidentiary Burden

The core of the MiFID II best execution requirement ▴ to take all sufficient steps to obtain the best possible result for clients ▴ remained firmly in place. What changed was the nature of the evidence required to demonstrate compliance. Without the public disclosures of RTS 27, an SI’s ability to compare its execution quality against other venues became significantly more challenging. The data points that were once standardized and publicly available, such as effective spread, likelihood of execution, and speed, now had to be sourced through other means or inferred from different datasets.

This shift placed a greater emphasis on the SI’s own [internal monitoring](https://prime.greeks.live/question/how-does-the-monitoring-of-information-leakage-in-rfq-protocols-differ-from-monitoring-lit-market-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) capabilities. The focus moved from a retrospective review of public reports to a real-time analysis of [internal execution](https://prime.greeks.live/question/how-can-a-firm-quantitatively-demonstrate-that-its-internal-order-routing-logic-upholds-its-best-execution-obligations/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) data, supplemented by whatever market data could be procured. The compliance function within SIs had to evolve, becoming more deeply integrated with trading desks and quantitative analysis teams to build a compelling narrative of best execution without the crutch of standardized regulatory reports. The nature of the conversation with regulators and clients changed, demanding a more sophisticated and evidence-based demonstration of the firm’s execution quality, rooted in its own operational data.

![Central metallic hub connects beige conduits, representing an institutional RFQ engine for digital asset derivatives. It facilitates multi-leg spread execution, ensuring atomic settlement, optimal price discovery, and high-fidelity execution within a Prime RFQ for capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-digital-asset-derivatives-rfq-protocol-execution-hub.jpg)

## From Public Data to Proprietary Analytics

The suspension of these reporting requirements was predicated on the view that the reports themselves were inefficient, costly, and ultimately failed to provide meaningful, comparable data for investors. Regulators in both the UK and EU noted the low readership and practical utility of the reports. For SIs, this meant the operational burden of producing RTS 27 reports was lifted, but the strategic challenge of proving best execution intensified. Compliance practices had to pivot towards a model that could construct a robust defense of execution quality using a mosaic of data points, including:

- **Internal Execution Metrics** ▴ Deep analysis of the SI’s own trading data, including fill rates, [price improvement](https://prime.greeks.live/area/price-improvement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) statistics, and latency measurements.

- **Third-Party [Transaction Cost Analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA)** ▴ Increased reliance on specialist TCA providers to benchmark execution performance against market-wide data.

- **Qualitative Assessments** ▴ More detailed and rigorous qualitative reviews of execution policies, venue selection, and order handling protocols.

- **Client Feedback and Due Diligence** ▴ Proactive engagement with clients to understand their execution preferences and demonstrate how the SI is meeting their specific needs.

This transition marked a maturation of the compliance function, moving it from a purely administrative role to a more strategic one. The absence of mandated reports forced a deeper, first-principles examination of what constitutes best execution and how it can be demonstrated in a complex and fragmented market environment.

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## Navigating the Post-Transparency Landscape

The strategic response of Systematic Internalisers to the cessation of RTS 27 and 28 reporting has been a decisive pivot towards internalizing and enhancing monitoring frameworks. With the external benchmark of public RTS 27 data removed, the strategic imperative became the creation of a resilient, evidence-based compliance system that could withstand regulatory scrutiny and client due diligence on its own merits. This involved a multi-pronged approach, focusing on bolstering internal data analytics, leveraging third-party data sources, and refining the qualitative oversight that governs execution policy. The primary goal was to construct a new evidentiary standard for best execution, one less reliant on standardized disclosures and more dependent on the firm’s ability to analyze and articulate its own performance within the broader market context.

This strategic shift has manifested in several key areas. First, there is a heightened focus on the granularity and sophistication of internal data capture and analysis. SIs are now compelled to develop and maintain their own proprietary benchmarks and performance metrics.

Second, the role of third-party data providers and TCA services has expanded significantly, filling the void left by the public reports. Third, the qualitative components of best execution monitoring, such as the regular review of execution policies and venue selection criteria, have taken on a greater importance, requiring more detailed documentation and justification.

> In the absence of mandated reports, SIs have strategically shifted their compliance focus to proprietary data analysis and enriched qualitative oversight to demonstrate best execution.

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## Fortifying Internal Monitoring Capabilities

The cornerstone of the new compliance strategy is the enhancement of internal monitoring systems. Without the ability to point to a standardized public report, SIs must now create a more compelling and self-contained narrative of their execution quality. This has necessitated significant investment in technology and expertise to capture, analyze, and report on a wide range of internal execution metrics. The focus is on demonstrating, with granular data, that the firm is consistently delivering high-quality execution for its clients.

This internal fortification involves several key initiatives:

- **Development of Proprietary Benchmarks** ▴ SIs are creating their own benchmarks to measure execution quality, tailored to their specific business models and client flows. These benchmarks often incorporate factors such as the time of day, market volatility, and order size to provide a more nuanced assessment of performance.

- **Real-Time Monitoring Dashboards** ▴ Compliance and trading teams are increasingly using real-time dashboards to monitor execution quality as it happens. This allows for the immediate identification and remediation of any potential issues, rather than waiting for a retrospective review.

- **Enhanced Reporting for Internal Governance** ▴ The level of detail and frequency of reporting to internal governance committees, such as the best execution committee, has increased. These reports provide a comprehensive overview of execution quality, highlighting trends, outliers, and any actions taken to improve performance.

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## The Expanded Role of Third-Party Data

While internal data forms the core of the new monitoring framework, SIs are also strategically increasing their reliance on third-party data providers and TCA services. These external sources provide a crucial market-wide context that is essential for benchmarking performance and demonstrating that the SI’s execution quality is competitive. The suspension of RTS 27 has, in effect, created a larger market for these specialized services.

The table below illustrates the shift in data sources used for SI [compliance monitoring](https://prime.greeks.live/area/compliance-monitoring/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) before and after the suspension of RTS 27/28 reporting.

| Data Source Category | Pre-Suspension Reliance | Post-Suspension Reliance |
| --- | --- | --- |

This strategic reallocation of resources towards more sophisticated data analysis and qualitative oversight reflects a maturation of the best execution framework. It moves beyond a compliance exercise based on public disclosure to a more integrated and dynamic system of performance management and risk control.

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## The Mechanics of a New Monitoring Protocol

The operational execution of SI compliance and monitoring practices, post-RTS 27/28, requires a fundamental re-engineering of internal processes and technological infrastructure. The abstract strategy of enhancing internal controls translates into concrete operational changes in how data is collected, analyzed, and acted upon. The focus of execution has shifted from the periodic, batch-based process of generating and reviewing public reports to a continuous, near-real-time monitoring system.

This system must be capable of ingesting a diverse range of data sources, applying sophisticated analytical models, and producing actionable insights for compliance officers, trading desks, and senior management. The new protocol is characterized by its dynamic nature, its reliance on a combination of quantitative and qualitative inputs, and its deep integration into the firm’s daily operations.

At the heart of this new operational model is the concept of a ‘best execution control loop’. This is a continuous cycle of data capture, analysis, review, and action that ensures the firm is not only meeting its regulatory obligations but also actively managing and improving its execution quality. This closed-loop system is a significant departure from the more static, report-driven approach of the past. It requires a more proactive and data-literate compliance function, working in close collaboration with technology and business teams to ensure the integrity and effectiveness of the monitoring process.

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## Implementing a Multi-Layered Analytical Framework

The practical implementation of a post-RTS 27/28 monitoring framework involves the deployment of a multi-layered analytical approach. This framework is designed to provide a holistic view of execution quality, from high-level summary metrics down to the individual order level. Each layer of the framework serves a specific purpose, providing different stakeholders with the information they need to perform their roles effectively.

The layers of this analytical framework typically include:

- **Macro-Level Performance Monitoring** ▴ This layer provides a high-level overview of the SI’s execution quality across all asset classes and client segments. It involves the tracking of key performance indicators (KPIs) such as average price improvement, spread capture, and fill rates over time. This information is typically presented in a dashboard format for senior management and governance committees.

- **Peer and Market Benchmarking** ▴ This layer involves the comparison of the SI’s internal performance data against market-wide benchmarks and peer group data obtained from third-party TCA providers. This provides the external context that was previously partially supplied by RTS 27 reports and is crucial for demonstrating the competitiveness of the SI’s execution.

- **Micro-Level Order Analysis** ▴ This is the most granular layer of the framework, involving the detailed analysis of individual orders or groups of orders. This ‘exception-based’ monitoring is designed to identify any instances of potential poor execution, which can then be investigated and remediated. This layer often involves the use of automated alerts and triggers to flag orders that fall outside of pre-defined tolerance levels.

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## Calibrating Monitoring Parameters and Thresholds

A critical execution task is the calibration of the quantitative parameters and thresholds that drive the monitoring framework. Without the standardized metrics of RTS 27, SIs must define their own internal standards for what constitutes ‘good’ execution. This is a complex process that requires a deep understanding of market microstructure, the firm’s own trading patterns, and the specific needs of its clients.

The following table provides an example of the types of revised monitoring parameters an SI might implement in the absence of RTS 27 data.

| Monitoring Parameter | Description | Example Threshold for Review |
| --- | --- | --- |

> Effective execution of SI compliance now hinges on a continuous control loop of data capture, multi-layered analysis, and dynamic threshold calibration.

The execution of this new monitoring protocol is an ongoing and iterative process. The parameters and thresholds must be regularly reviewed and updated to reflect changes in market conditions, the firm’s business mix, and regulatory expectations. The ultimate goal is to create a living, breathing compliance framework that provides a robust and defensible record of the firm’s commitment to achieving best execution for its clients, even in the absence of prescriptive public reporting requirements.

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## References

- FCA. “PS21/20 ▴ Reforms to UK MiFID’s conduct and organisational requirements.” Financial Conduct Authority, 30 Nov. 2021.

- European Securities and Markets Authority. “Public Statement on the deprioritisation of supervisory actions on the obligation to publish RTS 27 reports.” ESMA, 14 Dec. 2022.

- European Securities and Markets Authority. “MiFID II review ▴ ESMA’s proposals to amend the MiFID II framework to the benefit of investors.” ESMA, 2021.

- Directive (EU) 2021/338 of the European Parliament and of the Council of 16 February 2021 amending Directive 2014/65/EU as regards information requirements, product governance and position limits, and Directives 2013/36/EU and (EU) 2019/878 as regards their application to investment firms, to help the recovery from the COVID-19 crisis.

- Point Nine. “ESMA and FCA Suspends RTS 27.” Point Nine, 26 Mar. 2021.

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

- Ashurst. “EU changes to the MIFID regime are here.” Ashurst, 28 Mar. 2024.

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

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

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## From Mandated Disclosure to Inherent Resilience

The disappearance of the RTS 27 and 28 reporting regime has catalyzed a necessary evolution in the philosophy of compliance. The focus has shifted from an architecture of mandated public disclosure to one of inherent institutional resilience. The core question for a [Systematic Internaliser](https://prime.greeks.live/area/systematic-internaliser/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is no longer “Have we published the correct report?” but rather “Is our internal monitoring framework sufficiently robust to prove our value proposition without external validation?” This introspection forces a deeper engagement with the mechanics of execution quality, moving the entire discipline from a retrospective, compliance-driven exercise to a proactive, performance-oriented one. The absence of a standardized benchmark compels firms to create their own, tailored to their unique flow and client base, which ultimately fosters a more sophisticated and deeply embedded culture of best execution.

This new landscape presents an opportunity to build a more meaningful and effective compliance system. A framework born not of regulatory obligation but of operational necessity is invariably stronger. It integrates more seamlessly with the business, provides more actionable intelligence, and creates a more compelling narrative for both regulators and clients.

The challenge now lies in continuing to invest in the technology, talent, and governance structures that support this more demanding, yet ultimately more valuable, approach. The suspension of the reports was not an end to transparency, but the beginning of a new, more internally-driven and evidence-based era of accountability.

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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">
![A sophisticated modular component of a Crypto Derivatives OS, featuring an intelligence layer for real-time market microstructure analysis. Its precision engineering facilitates high-fidelity execution of digital asset derivatives via RFQ protocols, ensuring optimal price discovery and capital efficiency for institutional participants](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-module.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">
![Abstract forms depict interconnected institutional liquidity pools and intricate market microstructure. Sharp algorithmic execution paths traverse smooth aggregated inquiry surfaces, symbolizing high-fidelity execution within a Principal's operational framework](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-microstructure-prime-os-1.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/question/how-does-the-monitoring-of-information-leakage-in-rfq-protocols-differ-from-monitoring-lit-market-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Precision-engineered multi-layered architecture depicts institutional digital asset derivatives platforms, showcasing modularity for optimal liquidity aggregation and atomic settlement. This visualizes sophisticated RFQ protocols, enabling high-fidelity execution and robust pre-trade analytics](https://options.greeks.live/wp-content/uploads/2025/08/modular-digital-asset-derivative-prime-os-for-institutional-rfq-and-block-trade-execution.jpg)

## Monitoring Framework

Monitoring RFQ leakage involves profiling trusted counterparties' behavior, while lit market monitoring means detecting anonymous predatory patterns in public data. </a><a href="https://prime.greeks.live/question/how-do-mifid-ii-reporting-timelines-differ-between-public-trade-reports-and-regulatory-transaction-reports/?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)

## Public Reports

MiFID II mandates near real-time public reports for market transparency and detailed T+1 regulatory reports for market abuse surveillance. </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">
![Diagonal composition of sleek metallic infrastructure with a bright green data stream alongside a multi-toned teal geometric block. This visualizes High-Fidelity Execution for Digital Asset Derivatives, facilitating RFQ Price Discovery within deep Liquidity Pools, critical for institutional Block Trades and Multi-Leg Spreads on a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-digital-asset-derivatives-rfq-execution-optimization-leveraging-proprietary-institutional-prime-os-for-optimal-price-discovery-and-latency-reduction.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/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A stylized depiction of institutional-grade digital asset derivatives RFQ execution. A central glowing liquidity pool for price discovery is precisely pierced by an algorithmic trading path, symbolizing high-fidelity execution and slippage minimization within market microstructure via a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-high-fidelity-execution-1.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/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered metallic component displays two interlocking gold modules with circular execution apertures, anchored by a central pivot. This symbolizes an institutional-grade digital asset derivatives platform, enabling high-fidelity RFQ execution, optimized multi-leg spread management, and robust prime brokerage liquidity](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-core-for-institutional-trade-flow.jpg)

## Mifid Ii

Meaning ▴ MiFID II, the Markets in Financial Instruments Directive II, constitutes a comprehensive regulatory framework enacted by the European Union to govern financial markets, investment firms, and trading venues. </a><a href="https://prime.greeks.live/question/how-does-the-monitoring-of-information-leakage-in-rfq-protocols-differ-from-monitoring-lit-market-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A luminous central hub with radiating arms signifies an institutional RFQ protocol engine. It embodies seamless liquidity aggregation and high-fidelity execution for multi-leg spread strategies](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-hub-for-optimal-liquidity-aggregation.jpg)

## Internal Monitoring

Monitoring RFQ leakage involves profiling trusted counterparties' behavior, while lit market monitoring means detecting anonymous predatory patterns in public data. </a><a href="https://prime.greeks.live/question/how-can-a-firm-quantitatively-demonstrate-that-its-internal-order-routing-logic-upholds-its-best-execution-obligations/?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)

## Internal Execution

A firm proves its routing logic's integrity via a systematic TCA framework that validates every execution against empirical benchmarks. </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 sleek, light interface, a Principal's Prime RFQ, overlays a dark, intricate market microstructure. This represents institutional-grade digital asset derivatives trading, showcasing high-fidelity execution via RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-prime-os-execution-system.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/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated proprietary system module featuring precision-engineered components, symbolizing an institutional-grade Prime RFQ for digital asset derivatives. Its intricate design represents market microstructure analysis, RFQ protocol integration, and high-fidelity execution capabilities, optimizing liquidity aggregation and price discovery for block trades within a multi-leg spread environment](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-proprietary-architecture-driving-high-fidelity-digital-asset-derivatives-execution-via-rfq-protocols-and-optimized-market-microstructure-dynamics.jpg)

## 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/compliance-monitoring/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An abstract system depicts an institutional-grade digital asset derivatives platform. Interwoven metallic conduits symbolize low-latency RFQ execution pathways, facilitating efficient block trade routing](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-rfq-execution-engine.jpg)

## Compliance Monitoring

Meaning ▴ Compliance Monitoring constitutes the systematic, often automated, process of continuously scrutinizing an institution's operational activities, particularly within the domain of institutional digital asset derivatives, to ensure strict adherence to predefined regulatory obligations, internal policies, and market conduct rules. </a><a href="https://prime.greeks.live/area/systematic-internaliser/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A metallic, cross-shaped mechanism centrally positioned on a highly reflective, circular silicon wafer. The surrounding border reveals intricate circuit board patterns, signifying the underlying Prime RFQ and intelligence layer](https://options.greeks.live/wp-content/uploads/2025/08/the-core-institutional-digital-asset-derivatives-rfq-os-engine-for-high-fidelity-market-microstructure.jpg)

## 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>

**Tags:** [Execution Quality](https://options.greeks.live/area/execution-quality/), [Price Improvement](https://options.greeks.live/area/price-improvement/), [RTS 28](https://options.greeks.live/area/rts-28/), [Regulatory Reporting](https://options.greeks.live/area/regulatory-reporting/), [Transaction Cost Analysis](https://options.greeks.live/area/transaction-cost-analysis/), [Best Execution](https://options.greeks.live/area/best-execution/)	

## Discover More

- 
### [How Does the Suspension of RTS 27 and 28 Reports Affect a Firm’s Best Execution Obligations?](https://options.greeks.live/question/how-does-the-suspension-of-rts-27-and-28-reports-affect-a-firms-best-execution-obligations/)
![Central teal-lit mechanism with radiating pathways embodies a Prime RFQ for institutional digital asset derivatives. It signifies RFQ protocol processing, liquidity aggregation, and high-fidelity execution for multi-leg spread trades, enabling atomic settlement within market microstructure via quantitative analysis.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-core-for-institutional-digital-asset-rfq-protocol-execution-engine.jpg)

The suspension of RTS 27/28 shifts best execution from a reporting task to a continuous, evidence-based operational discipline.

- 
### [How Do Regulatory Changes like MiFID II Impact the Measurement and Reporting of Dark Pool Transaction Costs?](https://options.greeks.live/question/how-do-regulatory-changes-like-mifid-ii-impact-the-measurement-and-reporting-of-dark-pool-transaction-costs/)
![Abstract layers in grey, mint green, and deep blue visualize a Principal's operational framework for institutional digital asset derivatives. The textured grey signifies market microstructure, while the mint green layer with precise slots represents RFQ protocol parameters, enabling high-fidelity execution, private quotation, capital efficiency, and atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-layered-rfq-protocol-for-digital-asset-execution-system.jpg)

MiFID II mandates a granular, evidence-based system for measuring and reporting dark pool costs to enforce transparency and best execution.

- 
### [How Might the Proposed Removal of RTS 28 Reports Change EU Best Execution Strategy?](https://options.greeks.live/question/how-might-the-proposed-removal-of-rts-28-reports-change-eu-best-execution-strategy/)
![Two distinct, polished spherical halves, beige and teal, reveal intricate internal market microstructure, connected by a central metallic shaft. This embodies an institutional-grade RFQ protocol for digital asset derivatives, enabling high-fidelity execution and atomic settlement across disparate liquidity pools for principal block trades.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-high-fidelity-execution-prime-os.jpg)

The removal of RTS 28 reports shifts the best execution focus from public compliance to building a superior internal data and analytics framework.

- 
### [What Are the Key Differences in Proving Best Execution for Lit Markets versus Systematic Internalisers?](https://options.greeks.live/question/what-are-the-key-differences-in-proving-best-execution-for-lit-markets-versus-systematic-internalisers/)
![A slender metallic probe extends between two curved surfaces. This abstractly illustrates high-fidelity execution for institutional digital asset derivatives, driving price discovery within market microstructure. It represents Prime RFQ protocol precision navigating dark liquidity for best execution and capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/precision-instrument-navigating-institutional-digital-asset-derivatives-rfq-protocols-for-optimal-price-discovery-and-high-fidelity-execution.jpg)

Proving best execution shifts from measuring performance within a public auction to justifying a private price against that auction's outcome.

- 
### [Has the Suspension of RTS 27 Reporting Fundamentally Weakened the Best Execution Framework?](https://options.greeks.live/question/has-the-suspension-of-rts-27-reporting-fundamentally-weakened-the-best-execution-framework/)
![A sleek, multi-segmented sphere embodies a Principal's operational framework for institutional digital asset derivatives. Its transparent 'intelligence layer' signifies high-fidelity execution and price discovery via RFQ protocols. Distinct segments highlight integrated liquidity pools, atomic settlement, and optimized market microstructure for efficient multi-leg spread trading.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-digital-asset-derivatives-execution-engine.jpg)

The suspension of RTS 27 reporting refocused the best execution framework from public data compliance to internalized analytical accountability.

- 
### [How Do Rts 27 and Rts 28 Reports Interact to Ensure Best Execution Compliance?](https://options.greeks.live/question/how-do-rts-27-and-rts-28-reports-interact-to-ensure-best-execution-compliance/)
![A precision-engineered institutional digital asset derivatives execution system cutaway. The teal Prime RFQ casing reveals intricate market microstructure. Bright blue internal elements represent dynamic liquidity pools, enabling high-fidelity execution and efficient RFQ protocols for multi-leg spread strategies.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-rfq-protocol-core-engine.jpg)

RTS 27 and RTS 28 interact as a data feedback loop, where public venue performance data (RTS 27) informs and substantiates a firm's execution choices reported to clients (RTS 28).

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

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

- 
### [What Are the Key Differences in Best Execution Requirements between the UK and the EU Now?](https://options.greeks.live/question/what-are-the-key-differences-in-best-execution-requirements-between-the-uk-and-the-eu-now/)
![A translucent blue algorithmic execution module intersects beige cylindrical conduits, exposing precision market microstructure components. This institutional-grade system for digital asset derivatives enables high-fidelity execution of block trades and private quotation via an advanced RFQ protocol, ensuring optimal capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-core-execution-architecture-intelligence-layer.jpg)

UK and EU best execution rules now diverge on reporting, with the UK favouring internal evidence over the EU's prescribed reports.

- 
### [How Do Regulatory Changes like MiFID II Impact Smart Order Routing Strategies?](https://options.greeks.live/question/how-do-regulatory-changes-like-mifid-ii-impact-smart-order-routing-strategies/)
![A segmented teal and blue institutional digital asset derivatives platform reveals its core market microstructure. Internal layers expose sophisticated algorithmic execution engines, high-fidelity liquidity aggregation, and real-time risk management protocols, integral to a Prime RFQ supporting Bitcoin options and Ethereum futures trading.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-core-microstructure.jpg)

MiFID II compels Smart Order Routers to evolve from price-seekers into auditable, multi-factor optimization engines to prove best execution.

---

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---

**Original URL:** https://options.greeks.live/question/how-has-the-suspension-of-rts-27-and-rts-28-reporting-affected-si-compliance-and-monitoring-practices/
