# What Are the Key Differences in Best Execution Obligations between the Uk and the Eu Post-Brexit? ▴ Question

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

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![A precision optical system with a reflective lens embodies the Prime RFQ intelligence layer. Gray and green planes represent divergent RFQ protocols or multi-leg spread strategies for institutional digital asset derivatives, enabling high-fidelity execution and optimal price discovery within complex market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-intelligent-core-driving-digital-asset-derivatives-rfq-protocols-high-fidelity-execution-across-diverse-liquidity-pools-for-optimal-price-discovery.jpg)

![A multi-faceted digital asset derivative, precisely calibrated on a sophisticated circular mechanism. This represents a Prime Brokerage's robust RFQ protocol for high-fidelity execution of multi-leg spreads, ensuring optimal price discovery and minimal slippage within complex market microstructure, critical for alpha generation](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-precision-2.jpg)

## Concept

![A sleek, multi-component mechanism features a light upper segment meeting a darker, textured lower part. A diagonal bar pivots on a circular sensor, signifying High-Fidelity Execution and Price Discovery via RFQ Protocols for Digital Asset Derivatives](https://options.greeks.live/wp-content/uploads/2025/07/precision-engineered-institutional-digital-asset-derivatives-rfq-execution-microstructure-for-optimal-price-discovery-and-atomic-settlement-with-prime-os-integration.jpg)

## The Forking Paths of Obligation

The principle of [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), a foundational element of investor protection, persists as a shared objective between the United Kingdom and the European Union. Its core mandate requires investment firms to take all sufficient steps to obtain the best possible result for their clients when executing orders. This entails a holistic assessment of factors including price, costs, speed, likelihood of execution and settlement, size, and any other relevant consideration. The departure of the UK from the EU, however, has initiated a significant divergence in the regulatory architecture designed to achieve and evidence this objective.

This is not a superficial alteration of reporting lines; it represents a fundamental branching of regulatory philosophy, driven by distinct strategic priorities. The UK, through the [Financial Conduct Authority](https://prime.greeks.live/area/financial-conduct-authority/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (FCA), is recalibrating its framework to enhance the competitiveness and agility of its domestic markets. Conversely, the EU remains focused on maintaining a harmonized, prescriptive, and unified regulatory environment across its member states to ensure the integrity and stability of the single market.

This divergence manifests most clearly in the UK’s deliberate move away from certain prescriptive elements of the 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)), which has been onshored into UK law as “UK MiFID”. The UK’s approach favors a more principles-based system, entrusting regulators with [greater flexibility](https://prime.greeks.live/question/how-do-hybrid-cpu-fpga-systems-optimize-both-latency-and-strategic-flexibility/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) to tailor rules to the specific dynamics of the UK market. This strategic uncoupling is predicated on the view that overly rigid, one-size-fits-all mandates can create unintended consequences, such as stifling liquidity or imposing administrative burdens that outweigh their practical benefits for investor protection.

The result is a landscape where firms operating across both jurisdictions must navigate two increasingly distinct sets of rules governing how they execute trades, how they procure investment research, and how they report on their execution quality. Understanding these differences is a matter of operational necessity and strategic positioning.

> Post-Brexit, the UK and EU maintain the core principle of best execution but diverge significantly in the regulatory frameworks that define and enforce it.

![A central, metallic cross-shaped RFQ protocol engine orchestrates principal liquidity aggregation between two distinct institutional liquidity pools. Its intricate design suggests high-fidelity execution and atomic settlement within digital asset options trading, forming a core Crypto Derivatives OS for algorithmic price discovery](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-architecture-optimizing-liquidity-aggregation-and-high-fidelity-execution.jpg)

## Foundations of Divergence

The primary catalyst for this regulatory evolution is the UK’s newfound autonomy. Unbound from the EU’s extensive legislative process, which must accommodate the interests of 27 member states, the UK can enact changes with greater speed. This agility has been directed toward specific areas of MiFID II that were identified as particularly cumbersome or ill-suited to the UK’s [market structure](https://prime.greeks.live/area/market-structure/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). A prime example is the treatment of execution quality reporting under Regulatory Technical Standards (RTS) 27 and 28.

The FCA’s decision to abolish these reporting requirements stemmed from a pragmatic assessment of their utility, concluding that the cost and complexity of producing these reports were disproportionate to the value they provided to end investors. This action signals a broader philosophical shift ▴ a preference for outcomes-focused regulation over process-driven compliance.

In contrast, the EU’s approach remains anchored in the belief that detailed, harmonized rules are essential for creating a level playing field and preventing regulatory arbitrage within the single market. While the EU has also suspended certain reporting obligations, its actions have been more cautious, reflecting a continued commitment to the foundational principles of MiFID II’s transparency regime. This creates a dynamic where the UK is actively deconstructing and rebuilding parts of its regulatory house to a new design, while the EU is undertaking a more measured renovation of the existing structure.

For firms, this means that compliance can no longer be managed through a single, unified framework. Instead, it requires a bifurcated strategy that acknowledges and adapts to the unique regulatory currents of each jurisdiction.

![A symmetrical, multi-faceted structure depicts an institutional Digital Asset Derivatives execution system. Its central crystalline core represents high-fidelity execution and atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine-microstructure.jpg)

![A sleek, multi-segmented sphere embodies a Principal's operational framework for institutional digital asset derivatives. Its transparent 'intelligence layer' signifies high-fidelity execution and price discovery via RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-digital-asset-derivatives-execution-engine.jpg)

## Strategy

![Crossing reflective elements on a dark surface symbolize high-fidelity execution and multi-leg spread strategies. A central sphere represents the intelligence layer for price discovery](https://options.greeks.live/wp-content/uploads/2025/07/precision-algorithmic-trading-across-intersecting-liquidity-pools-for-institutional-digital-asset-derivatives-rfq-protocols.jpg)

## Navigating the Split in Reporting and Research

The most immediate strategic challenge for cross-jurisdictional firms arises from the divergence in reporting and research procurement rules. The UK’s complete abolition of [RTS 27](https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and [RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) reporting requirements simplifies the compliance landscape for firms operating solely within its purview. For those with an EU presence, however, the obligation to produce RTS 28 reports, which summarize the top five execution venues used, persists. This necessitates a dual compliance infrastructure.

Systems and processes must be maintained to capture and report the required data for EU clients and operations, while a different, less burdensome regime applies to UK business. This requires careful segmentation of data, workflows, and compliance oversight to ensure that the obligations of each jurisdiction are met without imposing unnecessary costs on the other.

A similar strategic bifurcation is required for investment research. The UK’s relaxation of the MiFID II “unbundling” rules allows firms to bundle payments for research and execution services under specific conditions, notably for research on smaller companies and in the fixed-income markets. This move is designed to stimulate research coverage where it has diminished. The EU’s “quick fix” also permits some re-bundling, but its scope is defined by different criteria, such as a higher corporate turnover threshold, and it is positioned as a temporary measure.

A firm’s strategic response must therefore consider how it sources and pays for research in each market. It may choose to adopt a bundled payment model in the UK to access a wider range of research on small and mid-cap stocks, while maintaining a strict unbundled approach in the EU to comply with its more restrictive rules. This decision has direct implications for budgeting, client agreements, and the management of conflicts of interest.

![Stacked, glossy modular components depict an institutional-grade Digital Asset Derivatives platform. Layers signify RFQ protocol orchestration, high-fidelity execution, and liquidity aggregation](https://options.greeks.live/wp-content/uploads/2025/07/layered-digital-asset-derivatives-rfq-protocol-stack-for-prime-brokerage.jpg)

## Comparative Analysis of Key Regulatory Changes

The table below outlines the specific points of divergence in reporting and research rules, providing a clear framework for strategic planning.

| Regulatory Area | United Kingdom Approach | European Union Approach |
| --- | --- | --- |
| RTS 27 Reporting (Execution Venues) | Abolished. The FCA determined the reports offered little practical value to investors. | Suspended/Deprioritized. The requirement has not been formally abolished, reflecting a more cautious stance. |
| RTS 28 Reporting (Investment Firms) | Abolished. Firms are no longer required to publish annual summaries of their top five execution venues. | Remains in force. Firms must continue to provide clients with this annual report. |
| Research Unbundling (Equities) | Relaxed. Bundled payments for research and execution are permitted for SMEs with a market capitalization below £200m. | Partially relaxed. A temporary “quick fix” allows bundling for companies with a turnover below €1bn, subject to specific client agreements. |
| Research Unbundling (Other) | Exemption from inducement rules for fixed-income research and research from independent providers not involved in execution. | Temporary re-bundling allowed for fixed-income research. |

![Central mechanical hub with concentric rings and gear teeth, extending into multi-colored radial arms. This symbolizes an institutional-grade Prime RFQ driving RFQ protocol price discovery for digital asset derivatives, ensuring high-fidelity execution across liquidity pools within market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/precision-institutional-digital-asset-derivatives-rfq-protocol.jpg)

## Recalibrating Market Structure and Transparency

Beyond reporting, the divergence extends into the fundamental architecture of market structure and transparency. The UK’s decision to remove the [Double Volume Cap](https://prime.greeks.live/area/double-volume-cap/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (DVC), a mechanism designed to limit the amount of trading that can occur in dark pools, reflects a strategic prioritization of liquidity. The regulatory calculus here is that the DVC, while intended to promote lit market trading, could inadvertently fragment liquidity and hinder efficient execution, particularly for large orders.

By removing this constraint, the UK aims to create a more attractive and liquid trading environment. In contrast, the EU is reinforcing its commitment to limiting dark trading by transitioning to a single [volume cap](https://prime.greeks.live/area/volume-cap/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) mechanism, underscoring its focus on price discovery within transparent, lit venues.

> Firms must now develop distinct venue selection strategies for the UK and EU, optimizing for liquidity in one and navigating volume caps in the other.

This divergence in transparency philosophy requires firms to adopt different [order routing](https://prime.greeks.live/area/order-routing/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and venue selection strategies for each jurisdiction. In the UK, there is greater flexibility to access dark liquidity without the constraints of the DVC. In the EU, firms must continue to monitor their dark pool usage closely to comply with the volume caps. Furthermore, the UK is implementing a more streamlined post-trade transparency regime, particularly for bonds and certain derivatives, aiming for a simpler and more timely reporting process.

A critical technical detail is the change in the scope of instruments “traded on a trading venue” (ToTV). For UK firms, this now applies only to instruments traded on UK venues, a change that complicates the determination of reporting obligations for firms dealing in a mix of UK and EU securities. This necessitates robust internal systems capable of accurately identifying the regulatory status of each instrument and applying the correct transparency rules based on its trading venue.

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![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)

## Execution

![A textured spherical digital asset, resembling a lunar body with a central glowing aperture, is bisected by two intersecting, planar liquidity streams. This depicts institutional RFQ protocol, optimizing block trade execution, price discovery, and multi-leg options strategies with high-fidelity execution within a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-optimized-rfq-execution-protocol-dynamic-liquidity-management.jpg)

## Operationalizing Dual Compliance Frameworks

The execution of a dual compliance strategy requires precise operational adjustments. Firms must re-architect their internal systems and workflows to function effectively across two distinct regulatory environments. This begins with the classification of clients and trades.

A robust system must be in place to flag whether a transaction falls under UK or EU jurisdiction, which then dictates the applicable rules for best execution evidence, reporting, and research charging. For reporting, this means configuring systems to generate RTS 28 reports only for the EU-facing side of the business, while decommissioning the corresponding processes for the UK to reduce operational overhead.

Order management systems (OMS) and execution management systems (EMS) require significant recalibration. Order routing logic must be sophisticated enough to account for the different market structures. For instance, an algorithm executing a large block order for a UK client might be programmed to preference dark venues to a greater degree than would be permissible for an EU client, due to the absence of the DVC in the UK.

This requires not just different routing tables but potentially different execution algorithms tailored to the liquidity and regulatory landscape of each market. The following steps outline a high-level operational plan for adaptation:

- **Jurisdictional Mapping** ▴ Conduct a full audit of all client accounts and trading flows to definitively map each to either the UK or EU regulatory regime. This forms the foundational data layer for all subsequent compliance controls. 

- **System Configuration** ▴ Reconfigure compliance and reporting systems to reflect the divergent rule sets. This involves creating separate rule engines for UK and EU trades to manage everything from transparency reporting to research payment attribution. 

- **Policy and Procedure Updates** ▴ Redraft all relevant policies, including the Best Execution Policy, Order Handling Policy, and Conflicts of Interest Policy. These documents must clearly articulate the different approaches taken in the UK and EU and be disseminated to all relevant staff. 

- **Training and Education** ▴ Implement a comprehensive training program for traders, compliance officers, and client-facing staff to ensure they understand the nuances of the two regimes and can execute their duties accordingly. 

![Metallic hub with radiating arms divides distinct quadrants. This abstractly depicts a Principal's operational framework for high-fidelity execution of institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-execution-prime-os-market-microstructure.jpg)

## Adapting to New Transparency Regimes

The practical execution of trading strategies is profoundly affected by the diverging transparency requirements. The UK’s move towards a more tailored and principles-based post-trade transparency system for non-equity instruments necessitates a re-evaluation of how and when trade data is reported. Firms must ensure their reporting workflows are updated to align with the FCA’s new timelines and data field requirements. The modification of the ToTV definition is a particularly critical operational point.

Systems that determine reporting obligations must be updated to use the UK’s narrower definition, which could reduce the reporting burden for some instruments but also introduces the risk of under-reporting if not implemented correctly. This requires close collaboration between compliance, technology, and trading teams to ensure the logic is sound.

> The divergence in transparency rules requires firms to implement sophisticated, jurisdiction-aware order routing and post-trade reporting systems.

The table below provides a granular comparison of the execution-level considerations related to transparency and market access, highlighting the operational adjustments required.

| Execution Parameter | UK Implementation | EU Implementation |
| --- | --- | --- |
| Dark Pool Access | Unconstrained by the Double Volume Cap (DVC). Order routers can be configured to more aggressively seek dark liquidity. | Constrained by the single volume cap. Requires continuous monitoring of execution volumes in dark venues to avoid breaches. |
| Post-Trade Transparency (Non-Equity) | A simpler regime with fewer deferrals is being implemented, requiring updates to reporting workflows to match new timelines. | The existing MiFID II framework largely remains, with its established set of deferrals and reporting requirements. |
| Systematic Internaliser (SI) Regime | The UK is reviewing its SI regime, with potential changes to quoting obligations and the definition of an SI. | The EU SI regime remains in place, with established thresholds and quoting obligations. |
| Share Trading Obligation (STO) | Removed. Firms have greater flexibility in choosing where to execute trades in shares, including non-UK venues. | Remains in place, requiring trades in certain EU-listed shares to be executed on EU-regulated venues. |

Finally, the removal of the [Share Trading Obligation](https://prime.greeks.live/area/share-trading-obligation/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (STO) in the UK provides firms with greater flexibility in their execution strategies for equities. They are no longer mandated to trade certain shares on UK- or EU-regulated markets and can seek liquidity on other international venues if it results in a better outcome for the client. This operational freedom requires firms to expand their venue analysis and connectivity to a wider range of global trading platforms. The execution strategy must now incorporate a global search for liquidity, guided by the overarching principle of achieving the best possible result, without the prescriptive geographical constraints that the STO previously imposed.

![Two distinct, polished spherical halves, beige and teal, reveal intricate internal market microstructure, connected by a central metallic shaft. This embodies an institutional-grade RFQ protocol for digital asset derivatives, enabling high-fidelity execution and atomic settlement across disparate liquidity pools for principal block trades](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-high-fidelity-execution-prime-os.jpg)

## References

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

- O’Hara, M. (1995). Market Microstructure Theory. Blackwell Publishing.

- Financial Conduct Authority. (2021). Changes to UK MiFID’s conduct and organisational requirements (Consultation Paper CP21/9).

- Financial Conduct Authority. (2023). Improving the UK’s primary and secondary markets (Policy Statement PS23/4).

- European Commission. (2021). Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions ▴ A Capital Markets Union for people and businesses-new action plan.

- Macfarlanes LLP. (2021). The UK’s post-Brexit balancing act begins with MiFID II.

- Slaughter and May. (2023). Financial Regulatory Divergence between the UK and EU.

- eflow Global. (2021). Best execution and beyond – What’s happening to RTS 27 & 28 post-Brexit? 

![Two abstract, segmented forms intersect, representing dynamic RFQ protocol interactions and price discovery mechanisms. The layered structures symbolize liquidity aggregation across multi-leg spreads within complex market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-microstructure.jpg)

## Reflection

![Abstract spheres and a translucent flow visualize institutional digital asset derivatives market microstructure. It depicts robust RFQ protocol execution, high-fidelity data flow, and seamless liquidity aggregation](https://options.greeks.live/wp-content/uploads/2025/07/precision-market-microstructure-for-institutional-digital-asset-derivatives-leveraging-rfq-protocols-and-atomic-settlement-across-prime-os.jpg)

## Two Systems One Principle

The divergence in best execution obligations between the UK and the EU is more than a technical adjustment; it is an ongoing experiment in regulatory design. On one side, a major financial center is betting on flexibility, principles, and market-led solutions to foster competitiveness. On the other, the world’s largest single market is reinforcing a rules-based, harmonized approach to ensure stability and uniformity. For institutional participants, navigating this evolving landscape is a test of adaptability.

The challenge lies in constructing an operational framework that is not merely compliant with two sets of rules, but is strategically optimized for both. This requires a deep understanding of the systemic goals behind each regulatory choice and the ability to translate that understanding into a coherent, dual-track execution strategy. The ultimate outcome of this divergence remains unwritten, but the firms that will thrive are those that view this complexity not as a burden, but as an opportunity to build a more sophisticated and resilient operational intelligence.

![A central RFQ aggregation engine radiates segments, symbolizing distinct liquidity pools and market makers. This depicts multi-dealer RFQ protocol orchestration for high-fidelity price discovery in digital asset derivatives, highlighting diverse counterparty risk profiles and algorithmic pricing grids](https://options.greeks.live/wp-content/uploads/2025/07/centralized-digital-asset-rfq-orchestration-for-multi-venue-liquidity-aggregation-and-high-fidelity-execution-across-diverse-counterparties.jpg)

## Glossary

<a href="https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An abstract visual depicts a central intelligent execution hub, symbolizing the core of a Principal's operational framework. Two intersecting planes represent multi-leg spread strategies and cross-asset liquidity pools, enabling private quotation and aggregated inquiry for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-engine-for-institutional-digital-asset-derivatives.jpg)

## Best Execution

Meaning ▴ Best Execution is the obligation to obtain the most favorable terms reasonably available for a client's order. </a><a href="https://prime.greeks.live/area/financial-conduct-authority/?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)

## Financial Conduct Authority

Meaning ▴ The Financial Conduct Authority operates as the conduct regulator for financial services firms and financial markets in the United Kingdom. </a><a href="https://prime.greeks.live/question/how-do-hybrid-cpu-fpga-systems-optimize-both-latency-and-strategic-flexibility/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![The image features layered structural elements, representing diverse liquidity pools and market segments within a Principal's operational framework. A sharp, reflective plane intersects, symbolizing high-fidelity execution and price discovery via private quotation protocols for institutional digital asset derivatives, emphasizing atomic settlement nodes](https://options.greeks.live/wp-content/uploads/2025/07/systemic-interplay-for-institutional-digital-asset-derivatives-execution-via-advanced-rfq-protocols.jpg)

## Greater Flexibility

A hybrid CPU-FPGA system surgically assigns tasks, using the FPGA for deterministic speed and the CPU for adaptive strategic intelligence. </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">
![Stacked, distinct components, subtly tilted, symbolize the multi-tiered institutional digital asset derivatives architecture. Layers represent RFQ protocols, private quotation aggregation, core liquidity pools, and atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/layered-institutional-digital-asset-derivatives-rfq-protocols-optimizing-principal-execution-management-systems-for-best-execution.jpg)

## Mifid Ii

Meaning ▴ MiFID II, the Markets in Financial Instruments Directive II, constitutes a comprehensive regulatory framework enacted by the European Union to govern financial markets, investment firms, and trading venues. </a><a href="https://prime.greeks.live/area/market-structure/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A futuristic system component with a split design and intricate central element, embodying advanced RFQ protocols. This visualizes high-fidelity execution, precise price discovery, and granular market microstructure control for institutional digital asset derivatives, optimizing liquidity provision and minimizing slippage](https://options.greeks.live/wp-content/uploads/2025/07/advanced-rfq-protocols-for-digital-asset-derivatives-price-discovery.jpg)

## Market Structure

Meaning ▴ Market structure defines the organizational and operational characteristics of a trading venue, encompassing participant types, order handling protocols, price discovery mechanisms, and information dissemination frameworks. </a><a href="https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek conduit, embodying an RFQ protocol and smart order routing, connects two distinct, semi-spherical liquidity pools. Its transparent core signifies an intelligence layer for algorithmic trading and high-fidelity execution of digital asset derivatives, ensuring atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-execution-engine-bridging-diverse-liquidity-pools-via-high-fidelity-rfq-protocol-orchestration.jpg)

## Rts 27

Meaning ▴ RTS 27 mandates that investment firms and market operators publish detailed data on the quality of execution of transactions on their venues. </a><a href="https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An abstract digital interface features a dark circular screen with two luminous dots, one teal and one grey, symbolizing active and pending private quotation statuses within an RFQ protocol. Below, sharp parallel lines in black, beige, and grey delineate distinct liquidity pools and execution pathways for multi-leg spread strategies, reflecting market microstructure and high-fidelity execution for institutional grade digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-displaying-multi-leg-execution-status-and-optimal-liquidity-pathways.jpg)

## Rts 28

Meaning ▴ RTS 28 refers to Regulatory Technical Standard 28 under MiFID II, which mandates investment firms and market operators to publish annual reports on the quality of execution of transactions on trading venues and for financial instruments. </a><a href="https://prime.greeks.live/area/double-volume-cap/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Translucent teal panel with droplets signifies granular market microstructure and latent liquidity in digital asset derivatives. Abstract beige and grey planes symbolize diverse institutional counterparties and multi-venue RFQ protocols, enabling high-fidelity execution and price discovery for block trades via aggregated inquiry](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-protocols-liquidity-aggregation.jpg)

## Double Volume Cap

Meaning ▴ The Double Volume Cap is a regulatory mechanism implemented under MiFID II, designed to restrict the volume of equity and equity-like instrument trading that can occur in non-transparent venues, specifically dark pools and certain types of systematic internalisers. </a><a href="https://prime.greeks.live/area/volume-cap/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Sharp, intersecting geometric planes in teal, deep blue, and beige form a precise, pointed leading edge against darkness. This signifies High-Fidelity Execution for Institutional Digital Asset Derivatives, reflecting complex Market Microstructure and Price Discovery](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-digital-asset-derivatives-rfq-market-microstructure-2.jpg)

## Volume Cap

Meaning ▴ A Volume Cap defines a predefined maximum quantity of a specific digital asset derivative that an execution system is permitted to trade within a designated time interval or through a particular venue. </a><a href="https://prime.greeks.live/area/order-routing/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Translucent circular elements represent distinct institutional liquidity pools and digital asset derivatives. A central arm signifies the Prime RFQ facilitating RFQ-driven price discovery, enabling high-fidelity execution via algorithmic trading, optimizing capital efficiency within complex market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-best-execution-framework.jpg)

## Order Routing

Meaning ▴ Order Routing is the automated process by which a trading order is directed from its origination point to a specific execution venue or liquidity source. </a><a href="https://prime.greeks.live/area/share-trading-obligation/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A deconstructed spherical object, segmented into distinct horizontal layers, slightly offset, symbolizing the granular components of an institutional digital asset derivatives platform. Each layer represents a liquidity pool or RFQ protocol, showcasing modular execution pathways and dynamic price discovery within a Prime RFQ architecture for high-fidelity execution and systemic risk mitigation](https://options.greeks.live/wp-content/uploads/2025/08/modular-institutional-digital-asset-derivatives-execution-framework-dissected-for-optimal-rfq-performance.jpg)

## Share Trading Obligation

Meaning ▴ A Share Trading Obligation constitutes a mandatory requirement for market participants to execute or settle a trade involving shares, or their digital asset equivalents, under predefined conditions and within specified parameters. </a>

**Tags:** [UK Financial Conduct Authority](https://options.greeks.live/area/uk-financial-conduct-authority/), [Double Volume Cap](https://options.greeks.live/area/double-volume-cap/), [Systematic Internaliser](https://options.greeks.live/area/systematic-internaliser/), [RTS 28](https://options.greeks.live/area/rts-28/), [EU Regulatory Framework](https://options.greeks.live/area/eu-regulatory-framework/), [Market Structure](https://options.greeks.live/area/market-structure/)	

## Discover More

- 
### [What Are the Long Term Consequences of MiFID II on Market Making in European Equities?](https://options.greeks.live/question/what-are-the-long-term-consequences-of-mifid-ii-on-market-making-in-european-equities/)
![A multi-layered electronic system, centered on a precise circular module, visually embodies an institutional-grade Crypto Derivatives OS. It represents the intricate market microstructure enabling high-fidelity execution via RFQ protocols for digital asset derivatives, driven by an intelligence layer facilitating algorithmic trading and optimal price discovery.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-facilitating-high-fidelity-execution-and-optimal-price-discovery.jpg)

MiFID II re-architected European market-making into a data-driven function favoring technological scale and quantifiable execution.

- 
### [What Are the Key Differences between a MiFID I and a MiFID II Compliant RFQ Workflow?](https://options.greeks.live/question/what-are-the-key-differences-between-a-mifid-i-and-a-mifid-ii-compliant-rfq-workflow/)
![A precision digital token, subtly green with a '0' marker, meticulously engages a sleek, white institutional-grade platform. This symbolizes secure RFQ protocol initiation for high-fidelity execution of complex multi-leg spread strategies, optimizing portfolio margin and capital efficiency within a Principal's Crypto Derivatives OS.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-platform-secure-rfq-protocol-initiation-for-optimal-block-trade-execution.jpg)

MiFID II transforms the RFQ from a private negotiation into a transparent, auditable, data-driven execution protocol.

- 
### [To What Extent Has the Regulation of Dark Pools Improved Overall Market Price Discovery?](https://options.greeks.live/question/to-what-extent-has-the-regulation-of-dark-pools-improved-overall-market-price-discovery/)
![Abstract institutional-grade Crypto Derivatives OS. Metallic trusses depict market microstructure. Transparent discs symbolize liquidity pools, implied volatility, and dark pools, crucial for RFQ protocols and block trade execution. This visualizes high-fidelity execution and price discovery for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-market-microstructure-optimizing-rfq-protocols-for-high-fidelity-execution-via-prime-os.jpg)

Regulatory frameworks have improved price discovery by forcing greater transparency and segmenting order flow, not by eliminating dark liquidity.

- 
### [How Has the Suspension of RTS 27 and RTS 28 Reporting Affected SI Compliance and Monitoring Practices?](https://options.greeks.live/question/how-has-the-suspension-of-rts-27-and-rts-28-reporting-affected-si-compliance-and-monitoring-practices/)
![A luminous central hub with radiating arms signifies an institutional RFQ protocol engine. It embodies seamless liquidity aggregation and high-fidelity execution for multi-leg spread strategies. Varied quadrants represent diverse market microstructure, optimizing capital efficiency within a principal's operational framework, mitigating counterparty risk.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-hub-for-optimal-liquidity-aggregation.jpg)

The suspension of RTS 27/28 shifted SI compliance from public reporting to robust, proprietary execution quality monitoring systems.

- 
### [How Can Transaction Cost Analysis Be Used to Comply with FINRA and MiFID II Best Execution Rules?](https://options.greeks.live/question/how-can-transaction-cost-analysis-be-used-to-comply-with-finra-and-mifid-ii-best-execution-rules/)
![A sophisticated digital asset derivatives trading mechanism features a central processing hub with luminous blue accents, symbolizing an intelligence layer driving high fidelity execution. Transparent circular elements represent dynamic liquidity pools and a complex volatility surface, revealing market microstructure and atomic settlement via an advanced RFQ protocol.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-high-fidelity-execution-framework-optimizing-market-microstructure-price-discovery-intelligence-layer.jpg)

TCA provides a quantitative, evidence-based framework to systematically demonstrate adherence to best execution principles for regulators.

- 
### [What Are the Core Differences between Best Execution Requirements in the US and Europe?](https://options.greeks.live/question/what-are-the-core-differences-between-best-execution-requirements-in-the-us-and-europe/)
![Two semi-transparent, curved elements, one blueish, one greenish, are centrally connected, symbolizing dynamic institutional RFQ protocols. This configuration suggests aggregated liquidity pools and multi-leg spread constructions. The precision illustrates high-fidelity execution within a Principal's operational framework, optimizing price discovery for digital asset derivatives, navigating complex market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-price-discovery-engine.jpg)

The core difference is a philosophical one: the US requires documented "reasonable diligence," while the EU demands data-driven proof of "all sufficient steps."

- 
### [How Does MiFID II Differentiate Best Execution for Retail Vs Professional Clients?](https://options.greeks.live/question/how-does-mifid-ii-differentiate-best-execution-for-retail-vs-professional-clients/)
![Precision-engineered abstract components depict institutional digital asset derivatives trading. A central sphere, symbolizing core asset price discovery, supports intersecting elements representing multi-leg spreads and aggregated inquiry. Surrounding structures denote a robust Prime RFQ framework for high-fidelity execution and capital efficiency within market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-microstructure-optimization.jpg)

MiFID II mandates a results-based "all sufficient steps" execution for retail and a process-based "all reasonable steps" for professionals.

- 
### [How Has MiFID II Influenced the Market Share of Systematic Internalisers?](https://options.greeks.live/question/how-has-mifid-ii-influenced-the-market-share-of-systematic-internalisers/)
![A central Prime RFQ core powers institutional digital asset derivatives. Translucent conduits signify high-fidelity execution and smart order routing for RFQ block trades. Peripheral modules symbolize aggregated liquidity pools, enabling precise price discovery, mitigating counterparty risk, and optimizing portfolio margin.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-liquidity-aggregation-engine.jpg)

MiFID II re-architected European markets, making Systematic Internalisers the primary venue for discreet, principal-based liquidity.

- 
### [How Do Regulatory Frameworks like MiFID II or Reg NMS Address Anonymity and Best Execution?](https://options.greeks.live/question/how-do-regulatory-frameworks-like-mifid-ii-or-reg-nms-address-anonymity-and-best-execution/)
![An abstract digital interface features a dark circular screen with two luminous dots, one teal and one grey, symbolizing active and pending private quotation statuses within an RFQ protocol. Below, sharp parallel lines in black, beige, and grey delineate distinct liquidity pools and execution pathways for multi-leg spread strategies, reflecting market microstructure and high-fidelity execution for institutional grade digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-displaying-multi-leg-execution-status-and-optimal-liquidity-pathways.jpg)

MiFID II and Reg NMS use transparency rules and data reporting to manage the conflict between anonymous trading and the mandate for best execution.

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---

**Original URL:** https://options.greeks.live/question/what-are-the-key-differences-in-best-execution-obligations-between-the-uk-and-the-eu-post-brexit/
