# What Are the Core Differences between MiFID II and CAT Requirements for RFQ Reporting? ▴ Question

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

---

![A sleek, multi-layered institutional crypto derivatives platform interface, featuring a transparent intelligence layer for real-time market microstructure analysis. Buttons signify RFQ protocol initiation for block trades, enabling high-fidelity execution and optimal price discovery within a robust Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-os-precision-execution-rfq-protocol-intelligence-layer.jpg)

![Abstract, layered spheres symbolize complex market microstructure and liquidity pools. A central reflective conduit represents RFQ protocols enabling block trade execution and precise price discovery for multi-leg spread strategies, ensuring high-fidelity execution within institutional trading of digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-for-high-fidelity.jpg)

## Concept

Analyzing the core distinctions between the European Union’s Markets in Financial Instruments Directive II ([MiFID II](https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)) and the United States’ [Consolidated Audit Trail](https://prime.greeks.live/area/consolidated-audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (CAT) for Request for Quote (RFQ) reporting requires an appreciation for their foundational philosophies. These regulatory frameworks are architectural responses to different market pressures and seek to achieve distinct supervisory goals. Their application to the bilateral price discovery process of an RFQ reveals a fundamental divergence in how each jurisdiction approaches market structure, data collection, and systemic risk oversight.

MiFID II represents a broad mandate to enhance the fairness, efficiency, and integrity of European financial markets. Its reporting requirements for RFQs are a component of a much larger transparency regime. The directive’s primary objective is to illuminate pricing and liquidity across a vast range of financial instruments, extending beyond equities to bonds, derivatives, and structured products. For an RFQ, this translates into a focus on pre-trade and post-trade transparency.

The system is designed to ensure that the market has visibility into the pricing of trades, even those initiated through off-venue, bilateral negotiations. The [reporting obligation](https://prime.greeks.live/question/what-is-the-operational-hierarchy-for-determining-the-reporting-obligation-in-an-otc-trade/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is a mechanism to bring light to formerly opaque corners of the market, thereby creating a more level playing field and providing regulators with the data needed to monitor for fair pricing and best execution.

> The core purpose of MiFID II’s RFQ reporting is to enforce market-wide price transparency, while CAT’s purpose is to create a complete, granular lifecycle audit trail of all US market activity.

In contrast, the CAT framework was born from a different imperative ▴ the need for a comprehensive, end-to-end surveillance tool for U.S. equity and options markets. Its design principle is the granular reconstruction of the entire lifecycle of an order, from inception through routing and execution. For an RFQ, CAT is less concerned with public price transparency and more focused on capturing every event associated with the solicitation and response process. The system seeks to provide regulators with an unprecedented ability to trace market behavior, identify manipulative activities, and understand the complex interplay of market participants during events like a flash crash.

The reporting of RFQ responses, particularly those that are electronically communicated and immediately actionable, becomes another critical data point in this vast, interconnected [audit trail](https://prime.greeks.live/area/audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This distinction in purpose ▴ market transparency versus lifecycle surveillance ▴ is the central axis around which all other differences between the two regimes revolve.

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

![A 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](https://options.greeks.live/wp-content/uploads/2025/07/precision-core-enabling-institutional-digital-asset-derivatives-rfq-execution.jpg)

## Strategy

For a financial institution operating across both European and U.S. markets, navigating the [RFQ reporting](https://prime.greeks.live/area/rfq-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) requirements of MiFID II and CAT demands a dual-track strategy. The compliance challenge extends beyond simple data submission; it involves fundamentally different data architectures, operational workflows, and strategic considerations for how liquidity is sourced and engaged. A cohesive strategy must address the unique jurisdictional philosophies and their impact on execution protocols.

![A sleek, metallic multi-lens device with glowing blue apertures symbolizes an advanced RFQ protocol engine. Its precision optics enable real-time market microstructure analysis and high-fidelity execution, facilitating automated price discovery and aggregated inquiry within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-engine-intelligence-layer.jpg)

## A Tale of Two Philosophies Jurisdiction and Scope

The strategic divergence begins with the jurisdictional and product scope of each regulation. MiFID II is a pan-European framework that casts a wide net over asset classes. Its RFQ reporting rules apply to equities, but also to a broad array of non-equity instruments like bonds and derivatives.

This requires firms to build a reporting infrastructure capable of handling the diverse data schemas and market conventions of multiple asset types. The reporting obligation is often triggered by the location of the investment firm or the trading venue, creating a complex web of responsibilities.

Conversely, CAT is a U.S.-centric regulation focused exclusively on NMS securities, which include listed equities and options. Its mandate is to create a single, unified audit trail for these specific products. For a global institution, this means that the very same trading desk might have to apply MiFID II rules for a European bond RFQ and CAT rules for a U.S. options RFQ. This necessitates a sophisticated rules engine within the firm’s [Order Management System](https://prime.greeks.live/area/order-management-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (OMS) or Execution [Management System](https://prime.greeks.live/question/what-is-the-relationship-between-an-order-management-system-and-an-execution-management-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (EMS) to correctly identify the applicable regulatory regime based on the instrument, client location, and trading desk.

![A precision-engineered control mechanism, featuring a ribbed dial and prominent green indicator, signifies Institutional Grade Digital Asset Derivatives RFQ Protocol optimization. This represents High-Fidelity Execution, Price Discovery, and Volatility Surface calibration for Algorithmic Trading](https://options.greeks.live/wp-content/uploads/2025/07/principal-operational-framework-precision-calibration-for-institutional-digital-asset-derivatives-rfq-protocol-high-fidelity-execution-prime-os-and-volatility-surface-optimization.jpg)

## How Do Reporting Triggers Differ between the Regimes?

The specific events that trigger a reporting obligation for an RFQ highlight the different objectives of the two regulations. MiFID II’s reporting is generally categorized into two distinct streams ▴ pre-trade transparency and post-[trade reporting](https://prime.greeks.live/area/trade-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

- 
**MiFID II Pre-Trade Transparency** For certain market participants, like Systematic Internalisers (SIs), there is an obligation to make quotes public, even in an RFQ context, under specific conditions. This is designed to provide the broader market with visibility into actionable prices. Waivers can be obtained for large-in-scale orders or for instruments with no liquid market, which is a critical strategic consideration for firms executing block trades via RFQ.

- 
**MiFID II Post-Trade Reporting** Once a trade is executed via an RFQ, the details (price, volume, time) must be made public through an [Approved Publication Arrangement](https://prime.greeks.live/area/approved-publication-arrangement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (APA) as close to real-time as technically possible. This ensures the market receives timely information on executed transactions.

CAT’s reporting triggers are event-driven and focused on the audit trail. The initial request for a quote itself is not reportable. The key reportable event is the receipt of responses to the RFQ, especially if they are communicated in a standard electronic format (like FIX) and are “immediately actionable.” This means both the firm soliciting quotes and all firms providing quotes have a reporting obligation. The solicitor must report the receipt of all responses, even from the losing bidders.

This creates a comprehensive record of the competitive landscape for that specific liquidity sourcing event. The subsequent order routing and execution events are then linked to this initial solicitation, providing a complete picture for regulators.

> A firm’s strategy must account for MiFID II’s focus on public data dissemination versus CAT’s comprehensive, non-public audit trail of every message and response.

The following table provides a strategic comparison of the core reporting parameters:

| Parameter | MiFID II (EU) | Consolidated Audit Trail (CAT) (US) |
| --- | --- | --- |
| Primary Goal | Market transparency (pre- and post-trade). | Comprehensive lifecycle surveillance and audit trail. |
| Jurisdiction | European Union and UK. | United States. |
| Asset Scope | Broad ▴ Equities, bonds, derivatives, structured products. | Narrow ▴ NMS equities and listed options. |
| Reportable RFQ Events | Post-trade execution details. Pre-trade quotes for certain entities (e.g. SIs). | Receipt of all firm, electronically communicated, and actionable responses to an RFQ. |
| Who Reports | Typically the executing firm or venue reports post-trade data. SIs report pre-trade quotes. | Both the solicitor (reporting receipt of responses) and all responders (reporting their quotes). |
| Reporting Destination | Approved Publication Arrangements (APAs) for public dissemination and Approved Reporting Mechanisms (ARMs) for regulatory reporting. | Central CAT repository for regulatory use only. |
| Anonymity | Post-trade reports are made public, often with deferred publication for large trades. Client data is masked from the public but reported to regulators. | All reported data is confidential to regulators. Firm and client identifiers are a core component of the data. |

![A modular institutional trading interface displays a precision trackball and granular controls on a teal execution module. Parallel surfaces symbolize layered market microstructure within a Principal's operational framework, enabling high-fidelity execution for digital asset derivatives via RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-institutional-digital-asset-derivatives-rfq-protocol-controls.jpg)

![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)

## Execution

Executing a compliant RFQ reporting framework across both MiFID II and CAT jurisdictions is a significant technological and operational undertaking. It requires a granular understanding of the specific data fields, message formats, and system architectures necessary to satisfy two fundamentally different regulatory models. Success hinges on the ability to capture, enrich, and route data correctly at every stage of the RFQ lifecycle.

![A precision-engineered metallic institutional trading platform, bisected by an execution pathway, features a central blue RFQ protocol engine. This Crypto Derivatives OS core facilitates high-fidelity execution, optimal price discovery, and multi-leg spread trading, reflecting advanced market microstructure](https://options.greeks.live/wp-content/uploads/2025/08/precision-engineered-institutional-digital-asset-derivatives-execution-core-facilitating-rfq-protocol-driven-optimal-price-discovery-and-multi-leg-spread-trading-for-capital-efficiency.jpg)

## The Architectural Blueprint for Dual Compliance

A robust compliance architecture must begin at the point of trade intention and extend through to post-execution reconciliation. The Order Management System (EMS) and Execution Management System (OMS) are the central nervous systems of this process. They must be configured to not only manage the RFQ workflow but also to serve as the primary data capture and enrichment engine.

The process can be broken down into several key stages:

- 
**Instrument and Counterparty Classification** Before an RFQ is even initiated, the system must identify the instrument’s regulatory context. Is it a MiFID II instrument (e.g. a European corporate bond) or a CAT-reportable instrument (e.g. a U.S. listed option)? Simultaneously, the system must classify all potential counterparties, identifying their Legal Entity Identifiers (LEIs) for MiFID II and their CAT Reporter IDs for CAT.

- 
**RFQ Event Capture** The system must be designed to log every event in the RFQ process with highly precise timestamps. For CAT, this includes the receipt of every electronic response, whether it was winning or losing. For MiFID II, the critical events are the publication of pre-trade quotes (if applicable) and the final execution details.

- 
**Data Enrichment and Validation** This is the most critical stage. Raw execution data is insufficient. The system must enrich this data with a host of regulatory-specific identifiers. This requires real-time lookups and data joins from multiple internal and external sources.

- 
**Jurisdiction-Specific Routing** Once a reportable event is captured and enriched, the system must route it to the correct destination. MiFID II reports are sent to Approved Reporting Mechanisms (ARMs) for regulatory submission and Approved Publication Arrangements (APAs) for public transparency. CAT reports are sent directly to the centralized CAT processor. This requires maintaining multiple, secure connections and understanding the specific submission protocols of each entity.

![A sphere split into light and dark segments, revealing a luminous core. This encapsulates the precise Request for Quote RFQ protocol for institutional digital asset derivatives, highlighting high-fidelity execution, optimal price discovery, and advanced market microstructure within aggregated liquidity pools](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-execution-framework-for-institutional-digital-asset-derivatives-request-for-quote-protocol-optimization.jpg)

## What Are the Critical Data Fields for RFQ Reporting?

The devil is in the details of the data fields. While there is some conceptual overlap (e.g. identifying the instrument and price), the specific requirements are distinct. The following table outlines some of the critical data elements for an executed RFQ under both regimes, illustrating the challenge of creating a unified data model.

| Data Element | MiFID II Requirement | CAT Requirement | Execution Consideration |
| --- | --- | --- | --- |
| Timestamp Granularity | Microseconds or nanoseconds, depending on the trading modality. | Millisecond precision is generally required, with synchronized clocks. | Systems must support high-precision timestamping across all relevant servers (OMS, FIX engines, matching engines). |
| Unique Identifier | Unique Trade Identifier (UTI) or Trade Confirmation Reference (TCR). | RFQID, where available, to link responses to a solicitation. | The firm’s systems must generate and manage these identifiers, ensuring they are correctly applied to all related reportable events. |
| Counterparty ID | Legal Entity Identifier (LEI) for all legal entities involved. | CAT Reporter ID for the firm submitting the report. Customer identifying information is also required. | Requires maintaining an accurate and up-to-date database of both LEIs and CAT IDs for all clients and counterparties. |
| Venue Identification | MIC code of the trading venue or “SI” for a Systematic Internaliser. | destination field indicating where an order was routed. For RFQs, this may be the counterparty’s CAT Reporter ID. | The OMS/EMS must be able to correctly populate the venue of execution based on the trade context. |
| Reportable Action | Publication of post-trade details (price, volume, time). | MEOA (Modify/Accept Order) for the winning response; MENO (New Order) for the solicitor’s order. Reporting receipt of all electronic responses. | The FIX protocol and internal messaging formats must be adapted to capture these specific event types. |
| Anonymity Flag | Flags for deferred publication for large-in-scale trades. | solicitationFlag must be set to ‘true’ for all RFQ responses. | Business logic must be embedded in the system to correctly apply these flags based on trade size, instrument liquidity, and workflow. |

![A sleek green probe, symbolizing a precise RFQ protocol, engages a dark, textured execution venue, representing a digital asset derivatives liquidity pool. This signifies institutional-grade price discovery and high-fidelity execution through an advanced Prime RFQ, minimizing slippage and optimizing capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-protocol-integration-for-high-fidelity-execution-and-institutional-liquidity-aggregation-on-prime-os.jpg)

## System Integration and FIX Protocol

From a technology perspective, the Financial Information eXchange (FIX) protocol is a cornerstone of RFQ workflows and regulatory reporting. However, standard FIX messages often need to be extended with custom tags to carry the necessary regulatory data. For example:

- 
**FIX for CAT** When a firm receives an RFQ response, its FIX engine must be able to parse or add tags that specify the solicitationFlag and the RFQID. The subsequent execution report messages must carry the appropriate CAT event type.

- 
**FIX for MiFID II** For post-trade reporting, the FIX messages capturing the trade details must contain fields for the LEIs of the counterparties, the UTI, and the MIC code of the venue. This information is then extracted, formatted, and sent to the ARM/APA.

This requires close collaboration between trading desk personnel, compliance officers, and technology teams to ensure that the firm’s systems, from the front-office EMS to the back-office reporting engines, are fully integrated and configured to meet the distinct demands of both MiFID II and CAT.

![A central glowing core within metallic structures symbolizes an Institutional Grade RFQ engine. This Intelligence Layer enables optimal Price Discovery and High-Fidelity Execution for Digital Asset Derivatives, streamlining Block Trade and Multi-Leg Spread Atomic Settlement](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-microstructure-core.jpg)

## References

- Gupta, Mahima, and Shashin Mishra. “MiFID II & MiFIR ▴ Reporting Requirements and Associated Operational Challenges.” Sapient Global Markets, 2016.

- Norton Rose Fulbright. “MiFID II | Transparency and reporting obligations.” 2023.

- FINRA. “CAT NMS Plan FAQ B44, B45.” Consolidated Audit Trail, 2025.

- European Securities and Markets Authority. “Questions and Answers on MiFID II and MiFIR market structures topics.” ESMA70-872942901-38, 2023.

- FINRA. “RFQ Overview Phase 2c & 2d CAT Reporting.” Consolidated Audit Trail, 2021.

- Lehalle, Charles-Albert, and Sophie Laruelle, editors. Market Microstructure in Practice. World Scientific Publishing, 2018.

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

![Central polished disc, with contrasting segments, represents Institutional Digital Asset Derivatives Prime RFQ core. A textured rod signifies RFQ Protocol High-Fidelity Execution and Low Latency Market Microstructure data flow to the Quantitative Analysis Engine for Price Discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-core-system-high-fidelity.jpg)

## Reflection

The examination of MiFID II and [CAT reporting](https://prime.greeks.live/area/cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) protocols for RFQs moves beyond a simple compliance checklist. It prompts a deeper inquiry into a firm’s data architecture and its capacity for strategic adaptation. Viewing these regulations as isolated operational burdens is a constrained perspective. A more advanced viewpoint sees them as systemic pressures that reveal the robustness and intelligence of a firm’s trading infrastructure.

The core question for any market participant is whether its operational framework is merely reactive, patching systems to meet each new rule, or if it is a cohesive, intelligent system designed for the complexities of a multi-jurisdictional market. The ultimate advantage lies in building an architecture where regulatory data capture is a seamless byproduct of an efficient, transparent, and superior execution process.

![An institutional-grade platform's RFQ protocol interface, with a price discovery engine and precision guides, enables high-fidelity execution for digital asset derivatives. Integrated controls optimize market microstructure and liquidity aggregation within a Principal's operational framework](https://options.greeks.live/wp-content/uploads/2025/07/proprietary-institutional-digital-asset-derivatives-rfq-protocol-engine-facilitating-high-fidelity-execution-and-granular-market-microstructure-analysis-for-prime-os.jpg)

## Glossary

<a href="https://prime.greeks.live/area/consolidated-audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A deconstructed mechanical system with segmented components, revealing intricate gears and polished shafts, symbolizing the transparent, modular architecture of an institutional digital asset derivatives trading platform. This illustrates multi-leg spread execution, RFQ protocols, and atomic settlement processes](https://options.greeks.live/wp-content/uploads/2025/07/deconstructed-principal-trading-system-revealing-core-mechanics-of-digital-asset-derivatives-execution.jpg)

## Consolidated Audit Trail

Meaning ▴ The Consolidated Audit Trail (CAT) is a comprehensive, centralized database designed to capture and track every order, quote, and trade across US equity and options markets. </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 precisely engineered multi-component structure, split to reveal its granular core, symbolizes the complex market microstructure of institutional digital asset derivatives. This visual metaphor represents the unbundling of multi-leg spreads, facilitating transparent price discovery and high-fidelity execution via RFQ protocols within a Principal's operational framework](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-digital-asset-derivatives-rfq-protocols-revealing-market-microstructure-for-high-fidelity-execution-and-atomic-settlement-within-principals-operational-framework.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-is-the-operational-hierarchy-for-determining-the-reporting-obligation-in-an-otc-trade/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Luminous blue drops on geometric planes depict institutional Digital Asset Derivatives trading. Large spheres represent atomic settlement of block trades and aggregated inquiries, while smaller droplets signify granular market microstructure data](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-digital-asset-derivatives-rfq-protocols-driving-high-fidelity-execution-and-optimal-liquidity-discovery.jpg)

## Reporting Obligation

The operational hierarchy for OTC trade reporting is a jurisdictional waterfall assigning reporting duties based on counterparty status. </a><a href="https://prime.greeks.live/area/audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, spherical white and blue module featuring a central black aperture and teal lens, representing the core Intelligence Layer for Institutional Trading in Digital Asset Derivatives. It visualizes High-Fidelity Execution within an RFQ protocol, enabling precise Price Discovery and optimizing the Principal's Operational Framework for Crypto Derivatives OS](https://options.greeks.live/wp-content/uploads/2025/07/precision-lens-for-institutional-digital-asset-derivatives-rfq-execution.jpg)

## Audit Trail

Meaning ▴ An Audit Trail is a chronological, immutable record of system activities, operations, or transactions within a digital environment, detailing event sequence, user identification, timestamps, and specific actions. </a><a href="https://prime.greeks.live/area/rfq-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Intersecting abstract geometric planes depict institutional grade RFQ protocols and market microstructure. Speckled surfaces reflect complex order book dynamics and implied volatility, while smooth planes represent high-fidelity execution channels and private quotation systems for digital asset derivatives within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-protocols-digital-asset-microstructure-execution.jpg)

## Rfq Reporting

Meaning ▴ RFQ Reporting denotes the systematic aggregation and analysis of data generated from Request for Quote (RFQ) protocols within electronic trading environments. </a><a href="https://prime.greeks.live/area/order-management-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A dark, precision-engineered core system, with metallic rings and an active segment, represents a Prime RFQ for institutional digital asset derivatives. Its transparent, faceted shaft symbolizes high-fidelity RFQ protocol execution, real-time price discovery, and atomic settlement, ensuring capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-core-for-high-fidelity-rfq-protocol-execution-and-atomic-settlement.jpg)

## Order Management System

Meaning ▴ A robust Order Management System is a specialized software application engineered to oversee the complete lifecycle of financial orders, from their initial generation and routing to execution and post-trade allocation. </a><a href="https://prime.greeks.live/question/what-is-the-relationship-between-an-order-management-system-and-an-execution-management-system/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Engineered components in beige, blue, and metallic tones form a complex, layered structure. This embodies the intricate market microstructure of institutional digital asset derivatives, illustrating a sophisticated RFQ protocol framework for optimizing price discovery, high-fidelity execution, and managing counterparty risk within multi-leg spreads on a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-stack-optimization.jpg)

## Management System

The OMS codifies investment strategy into compliant, executable orders; the EMS translates those orders into optimized market interaction. </a><a href="https://prime.greeks.live/area/trade-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract geometric representation of an institutional RFQ protocol for digital asset derivatives. Two distinct segments symbolize cross-market liquidity pools and order book dynamics](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-protocol-2.jpg)

## Trade Reporting

Meaning ▴ Trade Reporting mandates the submission of specific transaction details to designated regulatory bodies or trade repositories. </a><a href="https://prime.greeks.live/area/approved-publication-arrangement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Institutional-grade infrastructure supports a translucent circular interface, displaying real-time market microstructure for digital asset derivatives price discovery. Geometric forms symbolize precise RFQ protocol execution, enabling high-fidelity multi-leg spread trading, optimizing capital efficiency and mitigating systemic risk](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-request-for-quote-protocol-high-fidelity-execution-market-microstructure-intelligence-layer.jpg)

## Approved Publication Arrangement

Meaning ▴ An Approved Publication Arrangement (APA) is a regulated entity authorized to publicly disseminate post-trade transparency data for financial instruments, as mandated by regulations such as MiFID II and MiFIR. </a><a href="https://prime.greeks.live/area/cat-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A polished metallic needle, crowned with a faceted blue gem, precisely inserted into the central spindle of a reflective digital storage platter. This visually represents the high-fidelity execution of institutional digital asset derivatives via RFQ protocols, enabling atomic settlement and liquidity aggregation through a sophisticated Prime RFQ intelligence layer for optimal price discovery and alpha generation](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-optimization-for-high-fidelity-execution-and-liquidity-aggregation-via-prime-os-intelligence-layer.jpg)

## Cat Reporting

Meaning ▴ CAT Reporting, or Consolidated Audit Trail Reporting, mandates the comprehensive capture and reporting of all order and trade events across US equity and and options markets. </a>

**Tags:** [Consolidated Audit Trail](https://options.greeks.live/area/consolidated-audit-trail/), [Market Microstructure](https://options.greeks.live/area/market-microstructure/), [CAT Reporting](https://options.greeks.live/area/cat-reporting/), [Audit Trail](https://options.greeks.live/area/audit-trail/), [Order Management System](https://options.greeks.live/area/order-management-system/), [Systematic Internaliser](https://options.greeks.live/area/systematic-internaliser/)	

## Discover More

- 
### [What Are the Primary Data Points a Firm Must Capture to Satisfy Both FINRA and MiFID II?](https://options.greeks.live/question/what-are-the-primary-data-points-a-firm-must-capture-to-satisfy-both-finra-and-mifid-ii/)
![Intersecting opaque and luminous teal structures symbolize converging RFQ protocols for multi-leg spread execution. Surface droplets denote market microstructure granularity and slippage. This represents high-fidelity execution of institutional digital asset derivatives, optimizing price discovery and minimizing latency in dark pool environments.](https://options.greeks.live/wp-content/uploads/2025/07/rfq-protocols-for-digital-asset-derivatives-high-fidelity-execution.jpg)

Dual-jurisdictional compliance hinges on a unified data architecture that maps granular transaction data to FINRA and MiFID II requirements.

- 
### [What Are the Primary Data Points an OMS Must Capture for MiFID II Compliance in RFQ Trading?](https://options.greeks.live/question/what-are-the-primary-data-points-an-oms-must-capture-for-mifid-ii-compliance-in-rfq-trading/)
![A symmetrical, multi-faceted structure depicts an institutional Digital Asset Derivatives execution system. Its central crystalline core represents high-fidelity execution and atomic settlement. Distinct principal entities feature API integration points, symbolizing robust RFQ protocol connectivity for cross-asset liquidity aggregation and block trades.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine-microstructure.jpg)

A MiFID II-compliant OMS must capture a complete, time-stamped audit trail of the RFQ lifecycle for regulatory reporting and best execution.

- 
### [What Technological Capabilities Are Essential for Automated and Compliant Block Trade Reporting?](https://options.greeks.live/question/what-technological-capabilities-are-essential-for-automated-and-compliant-block-trade-reporting/)
![A dark, precision-engineered core system, with metallic rings and an active segment, represents a Prime RFQ for institutional digital asset derivatives. Its transparent, faceted shaft symbolizes high-fidelity RFQ protocol execution, real-time price discovery, and atomic settlement, ensuring capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-core-for-high-fidelity-rfq-protocol-execution-and-atomic-settlement.jpg)

Implementing automated, compliant block trade reporting necessitates robust systems for real-time data validation, secure transmission, and immutable audit trails.

- 
### [How Do Large in Scale Thresholds Differ across Various Asset Classes?](https://options.greeks.live/question/how-do-large-in-scale-thresholds-differ-across-various-asset-classes/)
![A geometric abstraction depicts a central multi-segmented disc intersected by angular teal and white structures, symbolizing a sophisticated Principal-driven RFQ protocol engine. This represents high-fidelity execution, optimizing price discovery across diverse liquidity pools for institutional digital asset derivatives like Bitcoin options, ensuring atomic settlement and mitigating counterparty risk.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-for-prime-os.jpg)

Large-In-Scale thresholds are asset-specific liquidity measures that enable discreet, high-volume trading to minimize market impact.

- 
### [What Are the Specific Post-Trade Reporting Requirements for a LIS Transaction?](https://options.greeks.live/question/what-are-the-specific-post-trade-reporting-requirements-for-a-lis-transaction/)
![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)

LIS post-trade reporting is a regulated system of deferred publication designed to balance market transparency with the need to minimize the price impact of large-volume trades.

- 
### [How Do Regulatory Changes like Mifid Ii Impact Rfq Dynamics and Dealer Behavior?](https://options.greeks.live/question/how-do-regulatory-changes-like-mifid-ii-impact-rfq-dynamics-and-dealer-behavior/)
![A symmetrical, intricate digital asset derivatives execution engine. Its metallic and translucent elements visualize a robust RFQ protocol facilitating multi-leg spread execution. This system optimizes market microstructure and price discovery, ensuring high-fidelity execution and aggregated inquiry for capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-best-execution.jpg)

MiFID II mandates an evolution of the RFQ protocol into a data-driven, electronic system to enforce auditable best execution.

- 
### [How Should a Firm’s Smart Order Router Be Architected to Handle Both Us and Eu Regulations?](https://options.greeks.live/question/how-should-a-firms-smart-order-router-be-architected-to-handle-both-us-and-eu-regulations/)
![A sleek, black and beige institutional-grade device, featuring a prominent optical lens for real-time market microstructure analysis and an open modular port. This RFQ protocol engine facilitates high-fidelity execution of multi-leg spreads, optimizing price discovery for digital asset derivatives and accessing latent liquidity.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-execution-engine-for-high-fidelity-price-discovery-and-latent-liquidity-aggregation-across-multi-leg-spreads.jpg)

A dual-jurisdiction SOR must be a modular, configurable, and data-driven system that can seamlessly adapt to the distinct regulatory and market landscapes of the US and EU.

- 
### [How Can Firms Systematically Address Data Fragmentation across Multiple Legacy Systems for CAT Compliance?](https://options.greeks.live/question/how-can-firms-systematically-address-data-fragmentation-across-multiple-legacy-systems-for-cat-compliance/)
![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)

Firms can systematically address data fragmentation by architecting a central data hub to unify, normalize, and govern all order event data.

- 
### [Can a Single Technology Platform Be Architected to Comply with Both Mifid Ii and Finra Rfq Requirements?](https://options.greeks.live/question/can-a-single-technology-platform-be-architected-to-comply-with-both-mifid-ii-and-finra-rfq-requirements/)
![Four sleek, rounded, modular components stack, symbolizing a multi-layered institutional digital asset derivatives trading system. Each unit represents a critical Prime RFQ layer, facilitating high-fidelity execution, aggregated inquiry, and sophisticated market microstructure for optimal price discovery via RFQ protocols.](https://options.greeks.live/wp-content/uploads/2025/07/modular-institutional-crypto-derivatives-trading-system-components.jpg)

A single platform can comply with both MiFID II and FINRA through a modular design using a compliance abstraction layer.

---

## Raw Schema Data

```json
{
    "@context": "https://schema.org",
    "@type": "BreadcrumbList",
    "itemListElement": [
        {
            "@type": "ListItem",
            "position": 1,
            "name": "Home",
            "item": "https://options.greeks.live"
        },
        {
            "@type": "ListItem",
            "position": 2,
            "name": "Question",
            "item": "https://options.greeks.live/question/"
        },
        {
            "@type": "ListItem",
            "position": 3,
            "name": "What Are the Core Differences between MiFID II and CAT Requirements for RFQ Reporting?",
            "item": "https://options.greeks.live/question/what-are-the-core-differences-between-mifid-ii-and-cat-requirements-for-rfq-reporting/"
        }
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "Organization",
    "@id": "https://greeks.live/#organization",
    "name": "Greeks.Live",
    "url": "https://greeks.live/",
    "description": "Greeks.live is the definitive toolkit for the professional options trader, dedicated to empowering our users with institutional-grade data, advanced analytics, and a comprehensive suite of trading tools designed to provide a decisive edge in the market. Every article and guide published under the Greeks.live name is a product of our deep commitment to data-driven analysis and our mission to support the global trading community.",
    "email": "support@greeks.live",
    "logo": {
        "@type": "ImageObject",
        "url": "https://options.greeks.live/wp-content/uploads/2025/07/Greeks.Live-Logo-Icon.svg"
    },
    "hasPart": [
        {
            "@type": "WebSite",
            "name": "About Us",
            "url": "https://about.greeks.live"
        },
        {
            "@type": "WebSite",
            "name": "App Download Page",
            "url": "https://about.greeks.live/#/download/basic_trade"
        },
        {
            "@type": "WebSite",
            "name": "Newcomers' Guide",
            "url": "https://twisty-sign-c8b.notion.site/Guide-for-Greeks-live-X-Deribit-Newbies-5a08a3052822427d800af6eaf3704c8d"
        },
        {
            "@type": "WebSite",
            "name": "Knowledge Base",
            "url": "https://linktr.ee/greeks.live"
        },
        {
            "@type": "WebSite",
            "name": "Option Terminology",
            "url": "https://greekslive.notion.site/88dfc00e7c584d4d8969b6302a79a12f?pvs=4"
        },
        {
            "@type": "WebSite",
            "name": "Terms of Service",
            "url": "https://greeks.live/#/tos"
        },
        {
            "@type": "WebSite",
            "name": "Disclaimer",
            "url": "https://greeks.live/#/disclaimer"
        }
    ],
    "sameAs": [
        "https://x.com/greekslive",
        "https://youtube.com/@greeks_live?si=-KjT0Lkw4WUCI0tD",
        "https://t.me/greekslive_notifications",
        "https://t.me/greekslive",
        "https://pinterest.com/greekslive/"
    ],
    "makesOffer": [
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "RFQ Platform",
                "url": "https://rfq.greeks.live",
                "description": "Execute institutional-grade block trades for crypto options and futures. This platform provides deep, over-the-counter (OTC) liquidity via a professional Request for Quote system.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Lending Tools",
                "url": "https://lend.greeks.live",
                "description": "Manage crypto lending and borrowing activities to earn yield or secure loans. This suite of tools helps users analyze interest rates and manage collateralized debt positions.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Data Lab",
                "url": "https://greeks.live/#/deribit/tools/datalab/BTC",
                "description": "Analyze historical and real-time options data with advanced metrics. This tool is designed for backtesting strategies and identifying market trends through comprehensive data visualization.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Profit & Loss Analysis (PnL)",
                "url": "https://greeks.live/#/deribit/tools/pnl_analysis",
                "description": "Track and analyze the Profit and Loss (PnL) of your options portfolio. This tool provides detailed performance metrics to help traders evaluate and refine their strategies.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Position Visualization",
                "url": "https://greeks.live/#/deribit/tools/pv/BTC",
                "description": "Visualize complex options positions and their corresponding risk profiles. This tool generates payoff diagrams to help traders intuitively understand potential profit, loss, and exposure.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Options Calculator",
                "url": "https://greeks.live/#/deribit/tools/calculator",
                "description": "Calculate the theoretical price and risk parameters ('the Greeks') of crypto options. An essential tool for pricing new trades and analyzing the sensitivity of existing positions.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live Main Platform",
                "url": "https://greeks.live/",
                "description": "The central hub for the Greeks.live suite of professional cryptocurrency options and derivatives trading tools. Access analytics, manage positions, and explore the ecosystem.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Community Forum",
                "url": "https://t.greeks.live",
                "description": "Join the official Greeks.live community. Connect with other traders, share insights, and receive the latest updates directly from the team.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live for Deribit",
                "url": "http://deribit.greeks.live",
                "description": "A dedicated interface for trading on the Deribit exchange. This platform leverages Greeks.live's advanced analytics and tools specifically for users of Deribit's options and futures markets.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live for OKX",
                "url": "http://okx.greeks.live",
                "description": "A dedicated interface for trading on the OKX exchange. This platform integrates Greeks.live's powerful analytics with the OKX marketplace, focusing on its options and derivatives products.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "GLVS.AI Trading Platform",
                "url": "https://www.glvs.ai/",
                "description": "An AI-powered platform for automated crypto options trading. Leverage advanced algorithms and data-driven signals to develop and deploy sophisticated, hands-free trading strategies.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "API Testnet & Sandbox",
                "url": "https://test.greeks.live",
                "description": "A dedicated testnet environment for developers to test their API integrations and automated trading strategies. This sandbox allows for full functionality testing without risking real funds.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        }
    ],
    "subOrganization": [
        {
            "@type": "Organization",
            "name": "GreeksLive HK Co., Limited",
            "email": "support@greeks.live",
            "telephone": "+852-56418949",
            "address": {
                "@type": "PostalAddress",
                "streetAddress": "Unit 11, 27/F, K. Wah Centre, 191 Java Road",
                "addressLocality": "Hong Kong",
                "addressRegion": "North Point",
                "addressCountry": "CN",
                "postalCode": "0000"
            },
            "geo": {
                "@type": "GeoCoordinates",
                "latitude": "22.2932357",
                "longitude": "114.2022026"
            },
            "image": "https://options.greeks.live/wp-content/uploads/2025/08/Wah-Centre-Hong-Kong.jpg"
        }
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "Article",
    "mainEntityOfPage": {
        "@type": "WebPage",
        "@id": "https://options.greeks.live/question/what-are-the-core-differences-between-mifid-ii-and-cat-requirements-for-rfq-reporting/"
    },
    "headline": "What Are the Core Differences between MiFID II and CAT Requirements for RFQ Reporting? \u25b4 Question",
    "description": "MiFID II mandates public price transparency for RFQs, while CAT requires a confidential, granular audit trail of the entire RFQ lifecycle. \u25b4 Question",
    "url": "https://options.greeks.live/question/what-are-the-core-differences-between-mifid-ii-and-cat-requirements-for-rfq-reporting/",
    "datePublished": "2025-08-06T16:07:29+00:00",
    "dateModified": "2025-08-06T16:07:30+00:00",
    "articleSection": [
        "Question"
    ],
    "author": {
        "@id": "https://greeks.live/#organization"
    },
    "publisher": {
        "@id": "https://greeks.live/#organization"
    },
    "image": {
        "@type": "ImageObject",
        "url": "https://options.greeks.live/wp-content/uploads/2025/07/precision-engineered-core-system-for-institutional-digital-asset-derivatives-rfq-protocol-execution-and-advanced-market-microstructure-optimization.jpg",
        "caption": "This image presents a meticulously engineered metallic component, a powerful visual metaphor for the sophisticated engine powering Institutional Digital Asset Derivatives trading. It embodies the Institutional Grade Prime RFQ, reflecting the granular precision vital for Market Microstructure analysis and High-Fidelity Execution. This core mechanism drives efficient RFQ Protocols, optimizing Price Discovery for Block Trades and Multi-Leg Spreads, leveraging Algorithmic Trading for Capital Efficiency and Best Execution across diverse Liquidity Pools."
    },
    "keywords": [
        "Approved Publication Arrangement",
        "Audit Trail",
        "CAT Reporting",
        "Consolidated Audit Trail",
        "Financial Regulation",
        "FIX Protocol",
        "Legal Entity Identifier",
        "Market Microstructure",
        "MiFID II",
        "Order Management System",
        "Regulatory Compliance",
        "RFQ Reporting",
        "Systematic Internaliser",
        "Trade Reporting"
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "WebSite",
    "url": "https://options.greeks.live/",
    "potentialAction": {
        "@type": "SearchAction",
        "target": "https://options.greeks.live/?s=search_term_string",
        "query-input": "required name=search_term_string"
    }
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "FAQPage",
    "mainEntity": [
        {
            "@type": "Question",
            "name": "How Do Reporting Triggers Differ Between The Regimes?",
            "acceptedAnswer": {
                "@type": "Answer",
                "text": "The specific events that trigger a reporting obligation for an RFQ highlight the different objectives of the two regulations. MiFID II's reporting is generally categorized into two distinct streams: pre-trade transparency and post-trade reporting."
            }
        },
        {
            "@type": "Question",
            "name": "What Are The Critical Data Fields For RFQ Reporting?",
            "acceptedAnswer": {
                "@type": "Answer",
                "text": "The devil is in the details of the data fields. While there is some conceptual overlap (e.g. identifying the instrument and price), the specific requirements are distinct. The following table outlines some of the critical data elements for an executed RFQ under both regimes, illustrating the challenge of creating a unified data model."
            }
        }
    ]
}
```


---

**Original URL:** https://options.greeks.live/question/what-are-the-core-differences-between-mifid-ii-and-cat-requirements-for-rfq-reporting/
