# What Are the Data Requirements for a Smart Order Router under the New MiFIR Rules? ▴ Question

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

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![An intricate mechanical assembly reveals the market microstructure of an institutional-grade RFQ protocol engine. It visualizes high-fidelity execution for digital asset derivatives block trades, managing counterparty risk and multi-leg spread strategies within a liquidity pool, embodying a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-architecture.jpg)

![The abstract composition features a central, multi-layered blue structure representing a sophisticated institutional digital asset derivatives platform, flanked by two distinct liquidity pools. Intersecting blades symbolize high-fidelity execution pathways and algorithmic trading strategies, facilitating private quotation and block trade settlement within a market microstructure optimized for price discovery and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-high-fidelity-execution-1.jpg)

## Concept

The implementation of the updated Markets in Financial Instruments Regulation, commonly known as [MiFIR](https://prime.greeks.live/area/mifir/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), fundamentally re-architected the role of a [Smart Order Router](https://prime.greeks.live/area/smart-order-router/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (SOR). An SOR is no longer a mere efficiency tool for sourcing liquidity at the best available price. It has been systematically redefined as a core component of a firm’s regulatory compliance and data-generation apparatus.

The primary mandate of MiFIR in this context is to enforce and evidence the principle of “best execution.” This requires the SOR to operate within a framework of extreme transparency, where every [routing decision](https://prime.greeks.live/question/how-does-firm-size-impact-the-oems-versus-best-of-breed-decision/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is not just made, but is also recorded, justified, and auditable. The [data requirements](https://prime.greeks.live/area/data-requirements/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) imposed by the regulation are the engineering specifications for this new class of SOR.

At its core, the challenge is one of data integrity and granularity. MiFIR compels an investment firm to prove, with verifiable data, that it has taken all sufficient steps to obtain the best possible result for its clients. This proof is not qualitative; it is quantitative, built upon a foundation of high-frequency data capture across the entire lifecycle of an order. The SOR sits at the epicenter of this data collection process.

It must be designed to capture not only the data points that inform its own routing logic ▴ such as price, volume, and latency ▴ but also a much wider universe of contextual [market data](https://prime.greeks.live/area/market-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This contextual data provides the necessary evidence to regulators that the chosen [execution venue](https://prime.greeks.live/area/execution-venue/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) was, in fact, the optimal choice among all available alternatives at that specific moment in time.

![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)

## The SOR as a Regulated Data Utility

Viewing the SOR as a regulated data utility is the correct architectural starting point. Its function extends beyond simple order routing to include the systematic capture, timestamping, and storage of data sufficient to reconstruct any trade and its surrounding market conditions. The regulations, particularly the [Regulatory Technical Standards](https://prime.greeks.live/area/regulatory-technical-standards/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (RTS) 27 and 28, dictate the specific outputs required.

RTS 27 focuses on the quality of execution from the perspective of the execution venues themselves, while RTS 28 requires investment firms to report on their top five execution venues and the quality of execution achieved. Although recent statements from the [European Securities](https://prime.greeks.live/question/how-does-the-double-volume-cap-directly-influence-algorithmic-trading-logic-for-european-equities/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and [Markets Authority](https://prime.greeks.live/question/what-is-the-role-of-the-designated-examining-authority-in-approving-a-voluntary-change-to-daily-computations/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (ESMA) have indicated a deprioritization of supervisory actions regarding these reports pending further review, the underlying obligation for best execution and the data capture to prove it remains firmly in place.

This transforms the SOR’s data handling requirements from an internal operational concern into a primary regulatory obligation. The system must be capable of ingesting a vast array of pre-trade data, processing it to make a compliant routing decision, and then logging every step of that process with microsecond precision. The data generated by the SOR becomes the raw material for the firm’s mandatory regulatory reporting and internal compliance oversight. Therefore, the design and [data architecture](https://prime.greeks.live/area/data-architecture/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) of the SOR are inextricably linked to the firm’s ability to meet its legal and regulatory duties under MiFIR.

> A Smart Order Router under MiFIR is an evidentiary engine, designed to prove best execution through granular, time-stamped data.

![A macro view of a precision-engineered metallic component, representing the robust core of an Institutional Grade Prime RFQ. Its intricate Market Microstructure design facilitates Digital Asset Derivatives RFQ Protocols, enabling High-Fidelity Execution and Algorithmic Trading for Block Trades, ensuring Capital Efficiency and Best Execution](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)

## Pre-Trade Transparency Data

The first category of data required by the SOR relates to [pre-trade transparency](https://prime.greeks.live/area/pre-trade-transparency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). To make a justifiable routing decision, the SOR must have access to a comprehensive view of the available liquidity across all potential [execution venues](https://prime.greeks.live/area/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This includes regulated markets, multilateral trading facilities (MTFs), organised trading facilities (OTFs), and systematic internalisers (SIs). The data ingested must be sufficient to construct a complete picture of the European Best Bid and Offer (EBBO) for a given instrument.

The SOR’s data feed handlers must be capable of processing and normalizing quote data from all these disparate sources in real-time. This includes not just the top-of-book prices but also the depth of the order book. For the SOR to make an informed decision, it needs to know the available volume at each price level.

Furthermore, the data must be timestamped upon receipt to allow for accurate latency calculations and to provide a verifiable record of the market conditions at the precise moment the routing decision was made. This pre-trade data forms the baseline against which the quality of the final execution will be measured.

![A sleek, futuristic object with a glowing line and intricate metallic core, symbolizing a Prime RFQ for institutional digital asset derivatives. It represents a sophisticated RFQ protocol engine enabling high-fidelity execution, liquidity aggregation, atomic settlement, and capital efficiency for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/advanced-institutional-digital-asset-derivatives-rfq-protocol-execution-engine-for-optimal-liquidity-aggregation-and-atomic-settlement.jpg)

## At-Trade Decision Logging

The second critical data category is the information generated and logged by the SOR at the moment of execution. This is the core of the evidentiary trail. When the SOR makes a routing decision, it must log not only where it sent the order but also why.

This requires the system to record the state of its own internal logic. For instance, if the SOR is configured to prioritize price, then cost, then speed, it must log the data points related to each of these factors for all considered venues at the time of the decision.

This “decision log” is a fundamental requirement. It must contain highly granular data, including:

- **Timestamps** ▴ The time the order was received by the SOR, the time the routing decision was made, and the time the order was sent to the execution venue, all with microsecond or better precision.

- **Venue Analysis** ▴ A record of all execution venues that were considered by the SOR’s logic, not just the one that was chosen.

- **[Best Execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Factors** ▴ The specific data points for each venue that were used in the decision, such as the quoted price, expected transaction costs, and historical likelihood of execution.

- **Order Characteristics** ▴ The details of the [client order](https://prime.greeks.live/question/how-can-a-firm-measure-the-toxicity-of-a-clients-order-flow/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) itself, including the instrument, size, order type, and any specific client instructions.

This at-trade data provides the direct evidence that the firm’s execution policy was followed and that the routing decision was made in the client’s best interest. Without this detailed log, a firm would be unable to defend its [execution quality](https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to regulators.

![Central intersecting blue light beams represent high-fidelity execution and atomic settlement. Mechanical elements signify robust market microstructure and order book dynamics](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-visualizing-market-microstructure-for-high-fidelity-alpha-generation-via-prime-os.jpg)

![A translucent blue cylinder, representing a liquidity pool or private quotation core, sits on a metallic execution engine. This system processes institutional digital asset derivatives via RFQ protocols, ensuring high-fidelity execution, pre-trade analytics, and smart order routing for capital efficiency on a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine-core-3.jpg)

## Strategy

The strategic imperative for an investment firm under MiFIR is to architect a [Smart Order](https://prime.greeks.live/question/how-do-smart-order-routers-decide-between-sending-an-order-to-an-exchange-versus-an-si/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Routing system that treats data as its primary asset. The design strategy must shift from a singular focus on execution performance to a dual focus on performance and provable compliance. This means the SOR’s logic and its data architecture must be developed in tandem, with the requirements of regulatory reporting shaping the very way the router analyzes markets and makes decisions. The goal is to build a system where compliance is an emergent property of a well-designed, data-centric execution process.

A successful strategy involves mapping the entire data lifecycle of an order, from its arrival at the firm to its final settlement and reporting. This data-centric approach ensures that at each stage of the process, the necessary data points are being captured, enriched, and stored in a manner that is both operationally useful and regulatorily sound. The SOR is the central node in this data lifecycle, acting as the point of maximum data convergence.

It is where pre-trade market data meets the client’s order, and where the decision to execute is made and recorded. Therefore, the strategy for the SOR must be a strategy for the firm’s entire [execution data](https://prime.greeks.live/area/execution-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) infrastructure.

![A sophisticated dark-hued institutional-grade digital asset derivatives platform interface, featuring a glowing aperture symbolizing active RFQ price discovery and high-fidelity execution. The integrated intelligence layer facilitates atomic settlement and multi-leg spread processing, optimizing market microstructure for prime brokerage operations and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-rfq-engine-intelligence-layer.jpg)

## Integrating Compliance into the Routing Logic

A key strategic decision is how to integrate the logic of best execution compliance directly into the SOR’s decision-making algorithm. A simplistic SOR might route an order based on the best displayed price. A MiFIR-compliant SOR must operate on a multi-factor model that considers all the best execution factors laid out in the regulation ▴ price, costs, speed, likelihood of execution and settlement, size, nature of the order, and any other relevant considerations. The SOR’s strategy must be to quantify these factors and use them as inputs into a weighted, auditable decision-making process.

This requires the SOR to have access to a rich set of supporting data beyond real-time market data. For example, to properly assess the “costs” factor, the SOR needs access to a database of execution venue fee schedules and an understanding of the potential for market impact. To assess the “likelihood of execution,” it needs access to historical data on the fill rates for different order types at different venues.

The strategy, therefore, involves creating a feedback loop where the results of past executions are used to enrich the data available for future routing decisions. This continuous improvement process is not just good for performance; it is also a key component of demonstrating to regulators that the firm is actively managing and improving its execution quality.

> A MiFIR-compliant SOR transforms regulatory constraints into a structured framework for making more intelligent and defensible routing decisions.

![A precision-engineered blue mechanism, symbolizing a high-fidelity execution engine, emerges from a rounded, light-colored liquidity pool component, encased within a sleek teal institutional-grade shell. This represents a Principal's operational framework for digital asset derivatives, demonstrating algorithmic trading logic and smart order routing for block trades via RFQ protocols, ensuring atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-os-core-algorithmic-execution-engine.jpg)

## Data Categorization for SOR Architecture

To implement this strategy, the data requirements for the SOR can be broken down into three main categories. This categorization provides a clear architectural blueprint for designing the system’s data handling capabilities. Each category represents a different type of data, with different requirements for sourcing, processing, and storage.

The following table outlines these data categories and their strategic importance for the SOR:

| Data Category | Description | Strategic Importance | Examples |
| --- | --- | --- | --- |
| Market Data (Dynamic) | Real-time, high-frequency data describing the state of the market. This data is volatile and time-sensitive. | Forms the basis of the pre-trade analysis. The quality and completeness of this data directly impact the SOR’s ability to identify the true best execution venue. | Level 1 and Level 2 order book data, trade prints, indices, and volatility surfaces. |
| Reference Data (Static) | Slow-moving, contextual data that provides essential information about the instruments, venues, and counterparties. | Provides the necessary context for the SOR to interpret market data and apply its routing logic correctly. Data accuracy is paramount. | Instrument identifiers (ISIN, CFI), venue fee schedules, trading calendars, and client-specific instructions. |
| Execution Data (Generated) | Data created by the SOR and other trading systems during the lifecycle of the order. This is the firm’s proprietary data. | Forms the evidentiary record for compliance. This data is the primary input for RTS 27/28 style reports and internal Transaction Cost Analysis (TCA). | Order timestamps, routing decisions, execution prices, fill quantities, and error messages. |

![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)

## How Does the SOR Use This Data Strategically?

The strategic integration of these data types allows the SOR to move beyond simple price-based routing. For example, when a large institutional order arrives, the SOR can execute a more sophisticated routing strategy:

- **Initial Analysis** ▴ The SOR ingests the client order (Execution Data) and identifies the instrument ([Reference Data](https://prime.greeks.live/area/reference-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)). It then pulls all relevant Market Data for that instrument from all connected venues.

- **Venue Scoring** ▴ Using its internal logic, the SOR scores each potential venue. It might weigh the displayed price heavily, but it will also use Reference Data to factor in the execution fees for each venue. It can also use historical Execution Data to assess the likelihood of a large order being fully executed without significant market impact at each venue.

- **Intelligent Slicing** ▴ Instead of sending the entire order to a single venue, the SOR might decide to slice the order into smaller pieces and route them to multiple venues simultaneously or over a short period. This decision is based on the depth of the order book (Market Data) and historical impact analysis (Execution Data).

- **[Audit Trail](https://prime.greeks.live/area/audit-trail/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Generation** ▴ Crucially, every step of this process is logged. The SOR records which venues were considered, how they were scored, and the rationale for the final slicing and routing strategy. This generated Execution Data is the proof of compliance.

This strategic approach ensures that the SOR is not just a “dumb” router but an intelligent system that actively manages the trade-off between execution quality and regulatory risk. The data it consumes and generates is the key to achieving both objectives.

![Internal, precise metallic and transparent components are illuminated by a teal glow. This visual metaphor represents the sophisticated market microstructure and high-fidelity execution of RFQ protocols for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-microstructure-prime-os-intelligence-layer-atomic-settlement-precision.jpg)

![A sharp, dark, precision-engineered element, indicative of a targeted RFQ protocol for institutional digital asset derivatives, traverses a secure liquidity aggregation conduit. This interaction occurs within a robust market microstructure platform, symbolizing high-fidelity execution and atomic settlement under a Principal's operational framework for best execution](https://options.greeks.live/wp-content/uploads/2025/07/principal-grade-digital-asset-derivatives-rfq-protocol-execution-engine.jpg)

## Execution

The execution phase of building or specifying a MiFIR-compliant Smart [Order Router](https://prime.greeks.live/question/how-does-a-smart-order-router-prioritize-different-venue-types-when-executing-a-large-order/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) involves translating the strategic data requirements into a concrete technical architecture and operational workflow. This is where the abstract principles of best execution are embodied in specific data fields, database schemas, and system-to-system communication protocols. The paramount objective is to create a system that captures the right data, at the right time, with the right level of precision, and makes that data available for reporting and analysis.

At this level of detail, the focus is on the granular data elements that the SOR must process and store. The design of the SOR’s data logs is a critical exercise. These logs are the definitive record of the firm’s compliance with its best execution obligations.

They must be immutable, easily queryable, and contain all the information necessary to satisfy a regulator’s request for information. The technical implementation must ensure that this data is captured without adding significant latency to the execution process itself, as speed of execution remains a key factor in achieving best execution.

![Abstract geometric forms in blue and beige represent institutional liquidity pools and market segments. A metallic rod signifies RFQ protocol connectivity for atomic settlement of digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-market-microstructure-1.jpg)

## Core Data Fields for the SOR Audit Trail

The foundation of a compliant SOR is its audit trail. This is more than a simple log of trades; it is a comprehensive record of the entire decision-making process. The following table details the essential data fields that must be captured for every single order processed by the SOR. These fields provide the raw data needed to construct the reports required by regulations like [RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and to conduct internal [Transaction Cost Analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA).

| Data Field | Description | MiFIR Relevance | Example Value |
| --- | --- | --- | --- |
| OrderID | A unique identifier for the client order. | Links all related log entries back to a single client instruction. | “ORD-20250805-12345” |
| InstrumentID_ISIN | The International Securities Identification Number of the financial instrument. | Unambiguously identifies the instrument being traded, as required for reporting. | “DE000BASF111” |
| Timestamp_OrderReceipt | The precise time the order was received by the firm’s systems, in UTC with microsecond precision. | Establishes the starting point for all latency and execution quality calculations. | “2025-08-05T09:25:10.123456Z” |
| Timestamp_Decision | The precise time the SOR made its final routing decision. | Allows for the calculation of internal processing latency (the “thinking time” of the SOR). | “2025-08-05T09:25:10.125890Z” |
| ConsideredVenues | An array of all execution venues that the SOR evaluated for the order. | Evidence that the firm considered all available sources of liquidity. | |
| VenueQuotes | An array of objects, with each object containing the best bid/ask and depth for each considered venue at the time of the decision. | Provides a snapshot of the market landscape, proving the basis for the price component of the decision. | |
| SelectedVenue | The execution venue to which the order (or a slice of the order) was routed. | The outcome of the routing decision. A primary field for RTS 28 reporting. | “XETR” |
| DecisionRationale | A code or description indicating the primary reason for the venue selection. | Explicitly states why a venue was chosen, linking the decision back to the firm’s execution policy. | “BEST_PRICE” or “LOWEST_COST” |
| ExecutionPrice | The price at which the order was executed. | The core data point for measuring price improvement or slippage. | 100.02 |
| ExecutionCosts | The total costs associated with the execution, including fees and commissions. | A critical component of the overall best execution assessment, as required by MiFIR. | 0.50 |
| Timestamp_Execution | The precise time of the execution at the venue. | Allows for the calculation of round-trip latency and comparison with market conditions at the time of execution. | “2025-08-05T09:25:10.250123Z” |

![A precision-engineered metallic cross-structure, embodying an RFQ engine's market microstructure, showcases diverse elements. One granular arm signifies aggregated liquidity pools and latent liquidity](https://options.greeks.live/wp-content/uploads/2025/07/institutional-rfq-engine-microstructure-for-atomic-settlement.jpg)

## What Is the Data Flow within the Execution System?

Understanding the flow of data is essential for proper implementation. The process can be visualized as a sequence of steps, each with specific data inputs and outputs.

- **Order Ingestion** ▴ A client order enters the firm’s Order Management System (OMS). The OMS enriches the order with client and reference data before passing it to the SOR.

- **Pre-Trade Analysis** ▴ The SOR receives the order. It immediately queries its market data handlers for a complete view of the lit and dark order books for the specified instrument. It also queries its internal reference data stores for venue costs and historical performance metrics.

- **Routing Decision** ▴ The SOR’s core logic processes all this data. It runs its scoring algorithm and makes a routing decision. At this point, it writes a detailed “decision log” entry containing the fields described in the table above. This is the most critical data capture event.

- **Execution and Capture** ▴ The SOR routes the order to the selected venue(s). The execution messages (fills) are returned from the venue and captured by the firm’s systems. These fills are used to update the SOR’s audit trail with the final execution price and timestamp.

- **Post-Trade Processing** ▴ The completed audit trail record is passed to downstream systems. This includes the firm’s Transaction Cost Analysis (TCA) engine, which analyzes the quality of the execution, and the regulatory reporting engine, which aggregates the data for RTS 28 reports.

This structured flow ensures that data is captured systematically and that a complete, auditable record exists for every order. The SOR is the heart of this process, acting as both the decision-maker and the primary record-keeper.

![Beige module, dark data strip, teal reel, clear processing component. This illustrates an RFQ protocol's high-fidelity execution, facilitating principal-to-principal atomic settlement in market microstructure, essential for a Crypto Derivatives OS](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-rfq-protocol-execution-engine.jpg)

## Data Storage and Retrieval Architecture

The final piece of the execution puzzle is the data storage and retrieval architecture. MiFIR requires that all relevant data be stored for a minimum of five years and be readily accessible to competent authorities upon request. This has significant implications for the firm’s data infrastructure.

The volume of data generated by a modern SOR is immense. A high-frequency trading environment can generate terabytes of log data per day. Therefore, the storage solution must be both scalable and cost-effective. Many firms adopt a tiered storage approach.

The most recent data (e.g. from the last 90 days) is kept in a high-performance, queryable database for immediate access by compliance and trading desks. Older data is migrated to a lower-cost, long-term storage solution, such as a cloud-based data lake. The key is to maintain a unified query interface that can access data from all tiers, allowing a regulator’s request for data from three years ago to be fulfilled efficiently. The choice of database technology is also critical. Time-series databases are often favored for this use case due to their efficiency in storing and querying timestamped data.

![A segmented, teal-hued system component with a dark blue inset, symbolizing an RFQ engine within a Prime RFQ, emerges from darkness. Illuminated by an optimized data flow, its textured surface represents market microstructure intricacies, facilitating high-fidelity execution for institutional digital asset derivatives via private quotation for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-intelligence-layer-for-institutional-digital-asset-derivatives-rfq.jpg)

## References

- European Securities and Markets Authority. (2017). Commission Delegated Regulation (EU) 2017/575 of 8 June 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council on markets in financial instruments with regard to regulatory technical standards for the data broadcasters are required to publish.

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

- Hill, A. (2016). MiFID II/R Fixed Income Best Execution Requirements RTS 27 & 28. International Capital Market Association (ICMA).

- Financial Conduct Authority. (2017). Markets in Financial Instruments Directive II Implementation ▴ Policy Statement II. PS17/14.

- European Securities and Markets Authority. (2024). Public Statement on the deprioritisation of supervisory actions on the obligation to publish RTS 28 reports in light of the agreement on the MiFID II/MiFIR review. ESMA35-335435667-5871.

![A digitally rendered, split toroidal structure reveals intricate internal circuitry and swirling data flows, representing the intelligence layer of a Prime RFQ. This visualizes dynamic RFQ protocols, algorithmic execution, and real-time market microstructure analysis for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-core-processing-architecture-visualized-through-interconnected-liquidity-networks.jpg)

## Reflection

The integration of MiFIR’s data mandates into a Smart Order Router is a formidable engineering challenge. It forces a systemic view of execution, where regulatory compliance and performance optimization are two facets of the same objective. The exercise of architecting a compliant SOR compels a firm to look deeply at its own operational processes, its data infrastructure, and the very logic it uses to interact with the market. What data does the firm currently capture?

What is missing? How can the feedback loop between execution, analysis, and future decision-making be tightened?

![Precision-engineered modular components, with transparent elements and metallic conduits, depict a robust RFQ Protocol engine. This architecture facilitates high-fidelity execution for institutional digital asset derivatives, enabling efficient liquidity aggregation and atomic settlement within market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-optimizing-high-fidelity-execution-and-liquidity-aggregation.jpg)

## Is Your Data Architecture an Asset or a Liability?

Ultimately, the regulations provide a non-negotiable blueprint for a data-centric execution framework. A firm that approaches these requirements as a mere compliance burden will build a system that is brittle and expensive to maintain. A firm that views them as a specification for a superior execution system will build a strategic asset. The data generated by a well-architected SOR is a source of profound market intelligence.

It can be used to refine execution algorithms, to better understand venue behavior, and to provide clients with a level of transparency that builds enduring trust. The question for every institution is whether its current data architecture is capable of supporting this future, or if it remains anchored to a past where data was a byproduct, not the purpose, of execution.

![Central translucent blue sphere represents RFQ price discovery for institutional digital asset derivatives. Concentric metallic rings symbolize liquidity pool aggregation and multi-leg spread execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-high-fidelity-execution-1.jpg)

## Glossary

<a href="https://prime.greeks.live/area/smart-order-router/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A multi-layered, circular device with a central concentric lens. It symbolizes an RFQ engine for precision price discovery and high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-for-precision-execution.jpg)

## Smart Order Router

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

## Mifir

Meaning ▴ MiFIR, the Markets in Financial Instruments Regulation, constitutes a foundational legislative framework within the European Union, enacted to enhance the transparency, efficiency, and integrity of financial markets. </a><a href="https://prime.greeks.live/area/data-requirements/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A chrome cross-shaped central processing unit rests on a textured surface, symbolizing a Principal's institutional grade execution engine. It integrates multi-leg options strategies and RFQ protocols, leveraging real-time order book dynamics for optimal price discovery in digital asset derivatives, minimizing slippage and maximizing capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/principals-high-fidelity-rfq-execution-digital-asset-derivatives-hub.jpg)

## Data Requirements

Meaning ▴ Data Requirements define the precise specifications for all information inputs and outputs essential for the design, development, and operational integrity of a robust trading system or financial protocol within the institutional digital asset derivatives landscape. </a><a href="https://prime.greeks.live/question/how-does-firm-size-impact-the-oems-versus-best-of-breed-decision/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central, metallic hub anchors four symmetrical radiating arms, two with vibrant, textured teal illumination. This depicts a Principal's high-fidelity execution engine, facilitating private quotation and aggregated inquiry for institutional digital asset derivatives via RFQ protocols, optimizing market microstructure and deep liquidity pools](https://options.greeks.live/wp-content/uploads/2025/07/prime-brokerage-digital-asset-rfq-execution-engine-microstructure.jpg)

## Routing Decision

Firm size dictates technological architecture; smaller firms favor specialized best-of-breed tools while larger firms require the consolidated control of an OEMS. </a><a href="https://prime.greeks.live/area/execution-venue/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precise central mechanism, representing an institutional RFQ engine, is bisected by a luminous teal liquidity pipeline. This visualizes high-fidelity execution for digital asset derivatives, enabling precise price discovery and atomic settlement within an optimized market microstructure for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-core-execution-system-1.jpg)

## Execution Venue

Meaning ▴ An Execution Venue refers to a regulated facility or system where financial instruments are traded, encompassing entities such as regulated markets, multilateral trading facilities (MTFs), organized trading facilities (OTFs), and systematic internalizers. </a><a href="https://prime.greeks.live/area/market-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central institutional Prime RFQ, showcasing intricate market microstructure, interacts with a translucent digital asset derivatives liquidity pool. An algorithmic trading engine, embodying a high-fidelity RFQ protocol, navigates this for precise multi-leg spread execution and optimal price discovery](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-navigating-digital-asset-derivative-liquidity.jpg)

## Market Data

Meaning ▴ Market Data comprises the real-time or historical pricing and trading information for financial instruments, encompassing bid and ask quotes, last trade prices, cumulative volume, and order book depth. </a><a href="https://prime.greeks.live/area/regulatory-technical-standards/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract geometric forms depict a Prime RFQ for institutional digital asset derivatives. A central RFQ engine drives block trades and price discovery with high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-optimizing-market-microstructure-for-high-fidelity-execution.jpg)

## Regulatory Technical Standards

Meaning ▴ Regulatory Technical Standards, or RTS, are legally binding technical specifications developed by European Supervisory Authorities to elaborate on the details of legislative acts within the European Union's financial services framework. </a><a href="https://prime.greeks.live/question/how-does-the-double-volume-cap-directly-influence-algorithmic-trading-logic-for-european-equities/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central, blue-illuminated, crystalline structure symbolizes an institutional grade Crypto Derivatives OS facilitating RFQ protocol execution. Diagonal gradients represent aggregated liquidity and market microstructure converging for high-fidelity price discovery, optimizing multi-leg spread trading for digital asset options](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-11.jpg)

## European Securities

The Double Volume Cap forces algorithmic logic to dynamically re-route trades from suspended dark pools to lit markets and periodic auctions. </a><a href="https://prime.greeks.live/question/what-is-the-role-of-the-designated-examining-authority-in-approving-a-voluntary-change-to-daily-computations/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central, metallic, complex mechanism with glowing teal data streams represents an advanced Crypto Derivatives OS. It visually depicts a Principal's robust RFQ protocol engine, driving high-fidelity execution and price discovery for institutional-grade digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-8.jpg)

## Markets Authority

The Designated Examining Authority validates a firm's operational integrity before sanctioning changes to its core financial reporting cycle. </a><a href="https://prime.greeks.live/area/data-architecture/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A metallic blade signifies high-fidelity execution and smart order routing, piercing a complex Prime RFQ orb. Within, market microstructure, algorithmic trading, and liquidity pools are visualized](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-prime-os-execution-precision.jpg)

## Data Architecture

Meaning ▴ Data Architecture defines the formal structure of an organization's data assets, establishing models, policies, rules, and standards that govern the collection, storage, arrangement, integration, and utilization of data. </a><a href="https://prime.greeks.live/area/pre-trade-transparency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A translucent institutional-grade platform reveals its RFQ execution engine with radiating intelligence layer pathways. Central price discovery mechanisms and liquidity pool access points are flanked by pre-trade analytics modules for digital asset derivatives and multi-leg spreads, ensuring high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-core-platform.jpg)

## Pre-Trade Transparency

Meaning ▴ Pre-Trade Transparency refers to the real-time dissemination of bid and offer prices, along with associated sizes, prior to the execution of a trade. </a><a href="https://prime.greeks.live/area/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![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)

## Execution Venues

Meaning ▴ Execution Venues are regulated marketplaces or bilateral platforms where financial instruments are traded and orders are matched, encompassing exchanges, multilateral trading facilities, organized trading facilities, and over-the-counter desks. </a><a href="https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![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)

## 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/question/how-can-a-firm-measure-the-toxicity-of-a-clients-order-flow/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A glossy, teal sphere, partially open, exposes precision-engineered metallic components and white internal modules. This represents an institutional-grade Crypto Derivatives OS, enabling secure RFQ protocols for high-fidelity execution and optimal price discovery of Digital Asset Derivatives, crucial for prime brokerage and minimizing slippage](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-platform-revealing-core-rfq-protocol-mechanisms-for-optimized-high-fidelity-execution.jpg)

## Client Order

A firm measures order flow toxicity by using volume-synchronized models to detect the statistical signatures of informed trading. </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">
![A sleek, disc-shaped system, with concentric rings and a central dome, visually represents an advanced Principal's operational framework. It integrates RFQ protocols for institutional digital asset derivatives, facilitating liquidity aggregation, high-fidelity execution, and real-time risk management](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-engine-digital-asset-derivatives-execution.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/question/how-do-smart-order-routers-decide-between-sending-an-order-to-an-exchange-versus-an-si/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![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)

## Smart Order

A Smart Order Router optimizes for best execution by routing orders to the venue offering the superior net price, balancing exchange transparency with SI price improvement. </a><a href="https://prime.greeks.live/area/execution-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Interconnected metallic rods and a translucent surface symbolize a sophisticated RFQ engine for digital asset derivatives. This represents the intricate market microstructure enabling high-fidelity execution of block trades and multi-leg spreads, optimizing capital efficiency within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-microstructure-1.jpg)

## Execution Data

Meaning ▴ Execution Data comprises the comprehensive, time-stamped record of all events pertaining to an order's lifecycle within a trading system, from its initial submission to final settlement. </a><a href="https://prime.greeks.live/area/reference-data/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sharp, teal blade precisely dissects a cylindrical conduit. This visualizes surgical high-fidelity execution of block trades for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-precision-execution-microstructure.jpg)

## Reference Data

Meaning ▴ Reference data constitutes the foundational, relatively static descriptive information that defines financial instruments, legal entities, market venues, and other critical identifiers essential for institutional operations within digital asset derivatives. </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 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)

## 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/question/how-does-a-smart-order-router-prioritize-different-venue-types-when-executing-a-large-order/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A symmetrical, multi-faceted digital structure, a liquidity aggregation engine, showcases translucent teal and grey panels. This visualizes diverse RFQ channels and market segments, enabling high-fidelity execution for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/precision-liquidity-aggregation-engine-for-digital-asset-derivatives-trading.jpg)

## Order Router

A Smart Order Router executes large orders by systematically navigating fragmented liquidity, prioritizing venues based on a dynamic optimization of cost, speed, and market impact. </a><a href="https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A dual-toned cylindrical component features a central transparent aperture revealing intricate metallic wiring. This signifies a core RFQ processing unit for Digital Asset Derivatives, enabling rapid Price Discovery and High-Fidelity Execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-core-best-execution-prime-os.jpg)

## Transaction Cost Analysis

Meaning ▴ Transaction Cost Analysis (TCA) is the quantitative methodology for assessing the explicit and implicit costs incurred during the execution of financial trades. </a><a href="https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A multi-faceted crystalline structure, featuring sharp angles and translucent blue and clear elements, rests on a metallic base. This embodies Institutional Digital Asset Derivatives and precise RFQ protocols, enabling High-Fidelity Execution](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-digital-asset-derivatives-rfq-market-microstructure.jpg)

## Rts 28

Meaning ▴ RTS 28 refers to Regulatory Technical Standard 28 under MiFID II, which mandates investment firms and market operators to publish annual reports on the quality of execution of transactions on trading venues and for financial instruments. </a>

**Tags:** [Execution Venue](https://options.greeks.live/area/execution-venue/), [MiFIR](https://options.greeks.live/area/mifir/), [Execution Quality](https://options.greeks.live/area/execution-quality/), [Audit Trail](https://options.greeks.live/area/audit-trail/), [Best Execution](https://options.greeks.live/area/best-execution/), [Execution Venues](https://options.greeks.live/area/execution-venues/)	

## Discover More

- 
### [What Are the Key Differences in Best Execution Requirements between Mifid Ii and Regulation Nms?](https://options.greeks.live/question/what-are-the-key-differences-in-best-execution-requirements-between-mifid-ii-and-regulation-nms/)
![A central illuminated hub with four light beams forming an 'X' against dark geometric planes. This embodies a Prime RFQ orchestrating multi-leg spread execution, aggregating RFQ liquidity across diverse venues for optimal price discovery and high-fidelity execution of institutional digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-orchestrating-high-fidelity-execution-and-optimal-price-discovery.jpg)

MiFID II requires a holistic, process-driven proof of best outcome; Reg NMS mandates price protection against a national best bid and offer.

- 
### [What Are the Key Differences between MiFID I and MiFID II Best Execution?](https://options.greeks.live/question/what-are-the-key-differences-between-mifid-i-and-mifid-ii-best-execution/)
![A sleek, metallic instrument with a central pivot and pointed arm, featuring a reflective surface and a teal band, embodies an institutional RFQ protocol. This represents high-fidelity execution for digital asset derivatives, enabling private quotation and optimal price discovery for multi-leg spread strategies within a dark pool, powered by a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-execution-for-optimal-liquidity-discovery.jpg)

MiFID II transformed best execution from a principle of conduct into a data-driven mandate requiring demonstrable proof of optimal outcomes.

- 
### [How Does MiFID II’s Best Execution Policy Impact the Use of Anonymous RFQs?](https://options.greeks.live/question/how-does-mifid-iis-best-execution-policy-impact-the-use-of-anonymous-rfqs/)
![An intricate, high-precision mechanism symbolizes an Institutional Digital Asset Derivatives RFQ protocol. Its sleek off-white casing protects the core market microstructure, while the teal-edged component signifies high-fidelity execution and optimal price discovery. A detailed circular dial suggests real-time implied volatility and quantitative analysis for portfolio margin.](https://options.greeks.live/wp-content/uploads/2025/07/precision-engineered-institutional-digital-asset-derivatives-rfq-protocol-high-fidelity-market-microstructure-optimization.jpg)

MiFID II mandates that anonymous RFQs be integrated into a data-rich, auditable framework, transforming them from discreet tools into fully accountable execution venues.

- 
### [How Does the SI Quoting Obligation Impact Best Execution Analysis?](https://options.greeks.live/question/how-does-the-si-quoting-obligation-impact-best-execution-analysis/)
![A sophisticated dark-hued institutional-grade digital asset derivatives platform interface, featuring a glowing aperture symbolizing active RFQ price discovery and high-fidelity execution. The integrated intelligence layer facilitates atomic settlement and multi-leg spread processing, optimizing market microstructure for prime brokerage operations and capital efficiency. This represents a robust crypto derivatives OS.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-crypto-derivatives-rfq-engine-intelligence-layer.jpg)

The SI quoting obligation integrates a firm's principal book as a formal venue, demanding data-driven proof of its superiority within best execution analysis.

- 
### [How Does the Best Execution Obligation Apply When a Firm Acts as a Systematic Internaliser?](https://options.greeks.live/question/how-does-the-best-execution-obligation-apply-when-a-firm-acts-as-a-systematic-internaliser/)
![A cutaway reveals the intricate market microstructure of an institutional-grade platform. Internal components signify algorithmic trading logic, supporting high-fidelity execution via a streamlined RFQ protocol for aggregated inquiry and price discovery within a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-execution-for-digital-asset-derivatives-via-rfq-protocols.jpg)

A Systematic Internaliser's best execution duty is met by proving its internal prices are superior to public markets through a data-driven, verifiable operational framework.

- 
### [What Are the Regulatory Expectations for Documenting Rfq-Based Best Execution?](https://options.greeks.live/question/what-are-the-regulatory-expectations-for-documenting-rfq-based-best-execution/)
![Abstract geometric forms, including overlapping planes and central spherical nodes, visually represent a sophisticated institutional digital asset derivatives trading ecosystem. It depicts complex multi-leg spread execution, dynamic RFQ protocol liquidity aggregation, and high-fidelity algorithmic trading within a Prime RFQ framework, ensuring optimal price discovery and capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-liquidity-aggregation-market-microstructure-high-fidelity-execution-alpha-generation-prime-os-capital-efficiency.jpg)

A firm must construct a verifiable, data-driven narrative that proves diligent execution for every RFQ trade.

- 
### [How Do Regulatory Frameworks like Mifid Ii Influence the Evolution of Electronic Trading Protocols?](https://options.greeks.live/question/how-do-regulatory-frameworks-like-mifid-ii-influence-the-evolution-of-electronic-trading-protocols/)
![A metallic, circular mechanism, a precision control interface, rests on a dark circuit board. This symbolizes the core intelligence layer of a Prime RFQ, enabling low-latency, high-fidelity execution for institutional digital asset derivatives via optimized RFQ protocols, refining market microstructure.](https://options.greeks.live/wp-content/uploads/2025/08/precision-rfq-protocol-engine-for-institutional-digital-asset-derivatives.jpg)

MiFID II architects market evolution by embedding transparency into trading protocols, compelling a systemic shift to data-driven execution.

- 
### [What Are the Specific Data Points Required in an Rts 27 Best Execution Report?](https://options.greeks.live/question/what-are-the-specific-data-points-required-in-an-rts-27-best-execution-report/)
![Intersecting translucent planes and a central financial instrument depict RFQ protocol negotiation for block trade execution. Glowing rings emphasize price discovery and liquidity aggregation within market microstructure. This visualizes high-fidelity execution for digital asset derivatives on a Prime RFQ intelligence layer.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-orchestration-for-high-fidelity-execution-across-prime-os.jpg)

RTS 27 reports require a granular, public disclosure of a venue's price, cost, speed, and execution likelihood data.

- 
### [How Does MiFID II’S”All Sufficient Steps”Standard Change a Firm’s Data Management Strategy?](https://options.greeks.live/question/how-does-mifid-iis-all-sufficient-steps-standard-change-a-firms-data-management-strategy/)
![A central glowing blue mechanism with a precision reticle is encased by dark metallic panels. This symbolizes an institutional-grade Principal's operational framework for high-fidelity execution of digital asset derivatives. It embodies RFQ processing, enabling price discovery within a deep liquidity pool, optimizing market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/precision-core-enabling-institutional-digital-asset-derivatives-rfq-execution.jpg)

MiFID II's "all sufficient steps" standard elevates data management from a compliance task to the core of a firm's execution strategy.

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                "text": "Understanding the flow of data is essential for proper implementation. The process can be visualized as a sequence of steps, each with specific data inputs and outputs.\n Order Ingestion: A client order enters the firm's Order Management System (OMS). The OMS enriches the order with client and reference data before passing it to the SOR. Pre-Trade Analysis: The SOR receives the order. It immediately queries its market data handlers for a complete view of the lit and dark order books for the specified instrument. It also queries its internal reference data stores for venue costs and historical performance metrics. Routing Decision: The SOR's core logic processes all this data. It runs its scoring algorithm and makes a routing decision. At this point, it writes a detailed \"decision log\" entry containing the fields described in the table above. This is the most critical data capture event. Execution and Capture: The SOR routes the order to the selected venue(s). The execution messages (fills) are returned from the venue and captured by the firm's systems. These fills are used to update the SOR's audit trail with the final execution price and timestamp. Post-Trade Processing: The completed audit trail record is passed to downstream systems. This includes the firm's Transaction Cost Analysis (TCA) engine, which analyzes the quality of the execution, and the regulatory reporting engine, which aggregates the data for RTS 28 reports.\n\nThis structured flow ensures that data is captured systematically and that a complete, auditable record exists for every order. The SOR is the heart of this process, acting as both the decision-maker and the primary record-keeper."
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                "text": "Ultimately, the regulations provide a non-negotiable blueprint for a data-centric execution framework. A firm that approaches these requirements as a mere compliance burden will build a system that is brittle and expensive to maintain. A firm that views them as a specification for a superior execution system will build a strategic asset. The data generated by a well-architected SOR is a source of profound market intelligence. It can be used to refine execution algorithms, to better understand venue behavior, and to provide clients with a level of transparency that builds enduring trust. The question for every institution is whether its current data architecture is capable of supporting this future, or if it remains anchored to a past where data was a byproduct, not the purpose, of execution."
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}
```


---

**Original URL:** https://options.greeks.live/question/what-are-the-data-requirements-for-a-smart-order-router-under-the-new-mifir-rules/
