# What Are the Practical Challenges of Complying with MiFID II's Best Execution Requirements? ▴ Question

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

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## Concept

The Markets in [Financial Instruments](https://prime.greeks.live/area/financial-instruments/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Directive II (MiFID II) fundamentally re-architected the principle of [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). It transformed the concept from a qualitative obligation into a quantitative, data-intensive engineering challenge. The core of this challenge resides in a firm’s capacity to build and maintain a sophisticated data architecture. This system must be capable of demonstrating, with verifiable evidence, that every step taken in the execution process was optimized for the client’s interest.

The directive mandates that firms must take all sufficient steps, not just reasonable ones, to achieve the best possible result for their clients. This shifts the burden of proof squarely onto the investment firm.

This directive requires a systemic approach. It is an exercise in building a coherent, auditable system from disparate and often non-standardized data sources. The practical difficulty arises from the need to capture, normalize, and analyze a vast stream of information from [execution venues](https://prime.greeks.live/area/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), internal order management systems (OMS), and market data providers. Firms are required to prove a negative ▴ that no better execution was reasonably available at the moment of the trade.

This requires a system that provides a complete, time-stamped narrative of every order, from the initial decision to the final settlement. The regulation demands a level of transparency that forces firms to view their trading infrastructure through the lens of a regulator.

> The central challenge of MiFID II best execution is architecting a system that can ingest, analyze, and report on a multitude of execution factors to prove optimal client outcomes.

![A transparent sphere, representing a granular digital asset derivative or RFQ quote, precisely balances on a proprietary execution rail. This symbolizes high-fidelity execution within complex market microstructure, driven by rapid price discovery from an institutional-grade trading engine, optimizing capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-precision-1.jpg)

## What Defines the Scope of Execution Venues

[Under MiFID](https://prime.greeks.live/question/what-are-the-operational-consequences-of-misreporting-under-mifid-ii-versus-a-reporting-failure-under-emir/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) II, the universe of execution venues expanded significantly, adding layers of complexity to the selection and monitoring process. The directive recognizes a broad array of platforms where a trade can be executed. Each of these venues produces data in different formats and with varying degrees of granularity, creating a substantial data integration challenge. Firms must develop a systematic process for evaluating these venues not just once, but on an ongoing basis.

This continuous assessment is a core requirement, demanding that firms have the technological capability to analyze venue performance and adjust their execution strategies accordingly. The selection of a venue is no longer a static choice but a dynamic, data-driven decision.

- **Regulated Markets (RMs)** These are traditional stock exchanges that operate under a specific regulatory framework, offering high levels of transparency.

- **Multilateral Trading Facilities (MTFs)** These are systems that bring together multiple third-party buying and selling interests in financial instruments in a way that results in a contract. They offer an alternative to traditional exchanges.

- **Organised Trading Facilities (OTFs)** A category introduced by [MiFID II](https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), OTFs are discretionary trading systems primarily for non-equity instruments like bonds and derivatives. They introduce a degree of human judgment into the execution process.

- **Systematic Internalisers (SIs)** These are investment firms that, on an organised, frequent, systematic, and substantial basis, deal on their own account when executing client orders outside of a regulated market, MTF, or OTF.

- **Over-the-Counter (OTC)** This includes bilateral trades that are not conducted on any formal trading venue, requiring a different approach to price discovery and execution analysis.

The directive compels firms to look beyond the historical relationship with a broker and to quantitatively justify their venue selection for each asset class. This means establishing a formal, evidence-based process for why one venue is chosen over another for a specific type of order. The firm’s [order execution policy](https://prime.greeks.live/area/order-execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) must explicitly state the factors influencing this choice and be rigorously applied. 

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![A sleek, institutional-grade device, with a glowing indicator, represents a Prime RFQ terminal. Its angled posture signifies focused RFQ inquiry for Digital Asset Derivatives, enabling high-fidelity execution and precise price discovery within complex market microstructure, optimizing latent liquidity](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-execution-terminal-facilitating-high-fidelity-price-discovery-and-optimal-liquidity-aggregation.jpg)

## Strategy

A successful strategy for MiFID II best execution compliance is built on a foundation of robust data governance and advanced analytics. It moves beyond a box-ticking exercise and treats the regulatory requirements as a framework for building a more efficient and transparent execution process. The primary strategic objective is to create a feedback loop where pre-trade analysis, real-time monitoring, and post-trade reporting continuously inform and improve [execution quality](https://prime.greeks.live/area/execution-quality/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This requires a significant investment in technology and a cultural shift within the firm, where compliance, trading, and technology teams work in close collaboration. 

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## Developing a Data-Driven Execution Policy

The cornerstone of a MiFID II compliance strategy is the firm’s Order [Execution Policy](https://prime.greeks.live/area/execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This document is a public declaration of how the firm will achieve the best possible results for its clients. Under MiFID II, this policy must be specific, detailed, and evidence-based. It needs to articulate, for each class of financial instrument, the relative importance of the various execution factors.

The directive outlines nine such factors, but the “four-fold test” of price, costs, speed, and likelihood of execution are paramount. The challenge is to create a policy that is flexible enough to adapt to different market conditions and order types, yet rigorous enough to stand up to regulatory scrutiny.

The policy must also detail the specific execution venues the firm will use and provide a clear rationale for their inclusion. This requires a systematic and ongoing due diligence process for each venue. Firms must be able to demonstrate why a particular venue is suitable for a specific type of trade and how it contributes to achieving the best outcome.

This involves a deep analysis of each venue’s liquidity profile, execution fees, and settlement efficiency. The policy is a living document that must be reviewed at least annually and whenever a material change occurs that could affect the firm’s ability to achieve best execution.

> A firm’s Order Execution Policy must evolve from a static legal disclosure into a dynamic, data-driven charter that governs all execution decisions.

![Abstract depiction of an advanced institutional trading system, featuring a prominent sensor for real-time price discovery and an intelligence layer. Visible circuitry signifies algorithmic trading capabilities, low-latency execution, and robust FIX protocol integration for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-high-fidelity-rfq-protocols.jpg)

## How Should Firms Structure Transaction Cost Analysis

[Transaction Cost Analysis](https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (TCA) is the primary tool for measuring and demonstrating best execution. MiFID II elevated the role of TCA from a simple post-trade review to an integral part of the entire trading lifecycle. An effective TCA strategy involves more than just calculating slippage against an arrival price.

It requires a multi-faceted approach that incorporates various benchmarks and analytical techniques to provide a holistic view of execution quality. The goal is to create a system that can identify patterns, highlight outliers, and provide actionable insights to traders and compliance officers.

The table below outlines a structured approach to TCA, moving from basic to advanced analytical methods. This tiered approach allows a firm to build its capabilities over time, starting with fundamental metrics and progressing to more sophisticated, context-aware analysis.

### TCA Framework Under MiFID II

| Analysis Tier | Methodology | Key Metrics | Strategic Application |
| --- | --- | --- | --- |
| Tier 1 Foundational | Post-trade analysis against standard benchmarks. This is the baseline for compliance. | Arrival Price Slippage Volume-Weighted Average Price (VWAP) Time-Weighted Average Price (TWAP) | Provides a basic assessment of execution costs and helps identify significant deviations from market averages. Essential for regulatory reporting. |
| Tier 2 Contextual | Analysis that incorporates order characteristics and market conditions at the time of the trade. | Participation Rate Analysis Volatility-Adjusted Slippage Spread-Cost Analysis | Offers a more nuanced view of performance by considering the difficulty of the trade. Helps to differentiate between skill and market impact. |
| Tier 3 Predictive | Pre-trade analysis using historical data and market models to forecast transaction costs and inform trading strategy. | Predicted Market Impact Optimal Trading Schedule Venue Probability Analysis | Shifts TCA from a reactive to a proactive tool. Allows traders to select the optimal execution strategy and venue based on data-driven forecasts. |

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## Execution

The execution of a MiFID II [best execution framework](https://prime.greeks.live/area/best-execution-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) translates strategy into operational reality. This is where the architectural plans for data systems and governance structures are implemented. The process is meticulous, requiring a granular focus on data integrity, reporting protocols, and the continuous monitoring of outcomes. Success in execution is measured by the ability to produce, on demand, a complete and coherent audit trail for any given trade, demonstrating that the firm’s policies were followed and that the client’s interests were paramount at every stage of the process.

![Three sensor-like components flank a central, illuminated teal lens, reflecting an advanced RFQ protocol system. This represents an institutional digital asset derivatives platform's intelligence layer for precise price discovery, high-fidelity execution, and managing multi-leg spread strategies, optimizing market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-for-optimal-execution.jpg)

## Implementing RTS 27 and RTS 28 Reporting

A significant operational challenge under MiFID II is the implementation of the Regulatory Technical Standards (RTS) 27 and 28. These standards mandate specific, highly detailed public disclosures about execution quality. They are designed to bring a new level of transparency to the market, allowing investors to compare the execution quality of different firms and venues.

**[RTS 27](https://prime.greeks.live/area/rts-27/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)** requires execution venues to publish quarterly reports on the quality of execution they provide. This data is a critical input for investment firms’ own analysis. The reports include detailed information on price, costs, speed, and likelihood of execution for individual financial instruments. The challenge for firms is to ingest this vast and complex data from multiple venues, normalize it, and incorporate it into their venue analysis process.

**[RTS 28](https://prime.greeks.live/area/rts-28/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)** requires investment firms to publish an annual report summarizing the top five execution venues they used for each class of financial instrument. The report must also include a qualitative summary of the execution quality obtained. Compiling this report is a major undertaking that requires the aggregation of a full year’s worth of trading data. The firm must be able to link every trade to a specific venue and demonstrate how its venue selection aligns with its [Order Execution](https://prime.greeks.live/area/order-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Policy.

> Effective compliance with RTS 27 and RTS 28 requires an automated, scalable data architecture capable of processing and analyzing vast quantities of execution data.

The table below provides a simplified example of the data points a firm would need to track to compile its RTS 28 report for a specific class of instruments, such as large-cap equities.

### Example Data for RTS 28 Top Five Venues Report (Large-Cap Equities)

| Execution Venue | Volume of Orders (Percentage) | Number of Orders (Percentage) | Percentage of Passive Orders | Percentage of Aggressive Orders | Percentage of Directed Orders |
| --- | --- | --- | --- | --- | --- |
| Systematic Internaliser A | 45% | 35% | 60% | 40% | 0% |
| Regulated Market X | 25% | 30% | 70% | 30% | 0% |
| MTF Y | 15% | 20% | 50% | 50% | 0% |
| Broker B (Executing on various venues) | 10% | 10% | N/A | N/A | 100% |
| Dark Pool Z | 5% | 5% | 100% | 0% | 0% |

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## Establishing a Governance and Monitoring Framework

A robust governance structure is the human element that oversees the technology and processes of the best execution framework. This typically takes the form of a Best Execution Committee or a similar oversight body. This committee is responsible for the ongoing review and approval of the Order Execution Policy, the assessment of execution quality reports, and the investigation of any deficiencies. The execution of this governance function requires a clear mandate, a defined escalation process, and the authority to implement changes to the firm’s trading practices. 

- **Committee Formation** The committee should be comprised of senior representatives from trading, compliance, risk, and technology. This cross-functional representation ensures that decisions are made with a holistic understanding of the business.

- **Mandate Definition** The committee’s terms of reference must be clearly documented. This includes the frequency of meetings, the scope of its authority, and its reporting lines to the firm’s senior management.

- **Data Review Process** The committee must establish a formal process for reviewing TCA reports and RTS 28 summaries. This process should include predefined thresholds for escalating poor performance and a clear methodology for investigating the root causes.

- **Policy Review and Update** The committee is responsible for the annual review of the Order Execution Policy. This review must take into account the firm’s own performance data, the RTS 27 reports from its execution venues, and any changes in the market structure.

- **Record Keeping** Meticulous records of all committee meetings, decisions, and actions must be maintained. These records are a critical part of the audit trail that demonstrates the firm’s commitment to the principles of best execution.

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## How Can Technology Bridge the Compliance Gap?

Technology is the enabler of an effective MiFID II best execution framework. Manual processes are inadequate for handling the volume and complexity of data required for compliance. A modern execution management system (EMS) or a dedicated TCA platform is essential. These systems automate the capture of trade data, provide sophisticated analytical tools, and generate the required regulatory reports.

The key is to build an integrated technology stack where data flows seamlessly from the front-office trading systems to the back-office compliance and reporting tools. This integration eliminates data silos and provides a single source of truth for all execution-related information, forming the backbone of a defensible compliance posture.

![An abstract composition of interlocking, precisely engineered metallic plates represents a sophisticated institutional trading infrastructure. Visible perforations within a central block symbolize optimized data conduits for high-fidelity execution and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-multi-leg-execution-layer.jpg)

## References

- Financial Conduct Authority. “Markets in Financial Instruments Directive II Implementation ▴ Policy Statement II.” PS17/14, July 2017.

- European Securities and Markets Authority. “Questions and Answers on MiFID II and MiFIR investor protection and intermediaries topics.” ESMA35-43-349, 2021.

- R. Madhavan, A. & S. Panchapagesan, V. “The Quality of Open- and Closing-Price Auctions ▴ A Comparison of the Frankfurt and New York Stock Exchanges.” Journal of Financial and Quantitative Analysis, vol. 41, no. 4, 2006, pp. 889-908.

- O’Hara, Maureen. Market Microstructure Theory. Blackwell Publishers, 1995.

- Angel, J. J. Harris, L. E. & Spatt, C. S. “Equity Trading in the 21st Century ▴ An Update.” Quarterly Journal of Finance, vol. 5, no. 1, 2015.

- Gomber, P. et al. “High-Frequency Trading.” Goethe University Frankfurt, Working Paper, 2011.

- Hasbrouck, Joel. Empirical Market Microstructure ▴ The Institutions, Economics, and Econometrics of Securities Trading. Oxford University Press, 2007.

- Aldridge, Irene. High-Frequency Trading ▴ A Practical Guide to Algorithmic Strategies and Trading Systems. John Wiley & Sons, 2013.

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## Reflection

The architectural demands of MiFID II’s best execution requirements compel a fundamental re-evaluation of a firm’s operational systems. The process of building a compliant framework forces an institution to map its data flows, scrutinize its decision-making processes, and quantify its performance in unprecedented detail. What begins as a regulatory mandate can become a blueprint for superior operational intelligence. Consider your own firm’s architecture.

Is it a reactive system designed merely to satisfy reporting obligations, or is it a proactive engine that leverages execution data to refine strategy and secure a persistent competitive advantage? The directive provides the specifications; the opportunity is to build a system that transcends compliance and achieves true execution excellence.

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## Glossary

<a href="https://prime.greeks.live/area/financial-instruments/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Financial Instruments

Meaning ▴ Financial instruments represent codified contractual agreements that establish specific claims, obligations, or rights concerning the transfer of economic value or risk between parties. </a><a href="https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, 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)

## 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/execution-venues/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A central RFQ engine orchestrates diverse liquidity pools, represented by distinct blades, facilitating high-fidelity execution of institutional digital asset derivatives. Metallic rods signify robust FIX protocol connectivity, enabling efficient price discovery and atomic settlement for Bitcoin options](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-engine-liquidity-orchestration.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/question/what-are-the-operational-consequences-of-misreporting-under-mifid-ii-versus-a-reporting-failure-under-emir/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sharp, teal-tipped component, emblematic of high-fidelity execution and alpha generation, emerges from a robust, textured base representing the Principal's operational framework. Water droplets on the dark blue surface suggest a liquidity pool within a dark pool, highlighting latent liquidity and atomic settlement via RFQ protocols for institutional digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-execution-protocol-for-institutional-digital-asset-options.jpg)

## Under Mifid

A MiFID II misreport corrupts market surveillance data; an EMIR failure hides systemic risk, creating distinct operational and reputational threats. </a><a href="https://prime.greeks.live/area/mifid-ii/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision 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)

## 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/order-execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![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)

## Order Execution Policy

Meaning ▴ An Order Execution Policy defines the systematic procedures and criteria governing how an institutional trading desk processes and routes client or proprietary orders across various liquidity venues. </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 modular system with beige and mint green components connected by a central blue cross-shaped element, illustrating an institutional-grade RFQ execution engine. This sophisticated architecture facilitates high-fidelity execution, enabling efficient price discovery for multi-leg spreads and optimizing capital efficiency within a Prime RFQ framework for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/principal-prime-os-rfq-engine-for-digital-asset-derivatives.jpg)

## Execution Quality

Meaning ▴ Execution Quality quantifies the efficacy of an order's fill, assessing how closely the achieved trade price aligns with the prevailing market price at submission, alongside consideration for speed, cost, and market impact. </a><a href="https://prime.greeks.live/area/execution-policy/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered interface for institutional digital asset derivatives. A circular system component, perhaps an Execution Management System EMS module, connects via a multi-faceted Request for Quote RFQ protocol bridge to a distinct teal capsule, symbolizing a bespoke block trade](https://options.greeks.live/wp-content/uploads/2025/07/precision-engineered-interface-for-institutional-digital-asset-derivatives-request-for-quote-protocol-high-fidelity-execution-within-principal-operating-system.jpg)

## Execution Policy

Meaning ▴ An Execution Policy defines a structured set of rules and computational logic governing the handling and execution of financial orders within a trading system. </a><a href="https://prime.greeks.live/area/transaction-cost-analysis/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A Principal's RFQ engine core unit, featuring distinct algorithmic matching probes for high-fidelity execution and liquidity aggregation. This price discovery mechanism leverages private quotation pathways, optimizing crypto derivatives OS operations for atomic settlement within its systemic architecture](https://options.greeks.live/wp-content/uploads/2025/08/principals-rfq-engine-driving-optimal-digital-asset-derivatives.jpg)

## Transaction Cost Analysis

Meaning ▴ Transaction Cost Analysis (TCA) is the quantitative methodology for assessing the explicit and implicit costs incurred during the execution of financial trades. </a><a href="https://prime.greeks.live/area/best-execution-framework/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A polished metallic modular hub with four radiating arms represents an advanced RFQ execution engine. This system aggregates multi-venue liquidity for institutional digital asset derivatives, enabling high-fidelity execution and precise price discovery across diverse counterparty risk profiles, powered by a sophisticated intelligence layer](https://options.greeks.live/wp-content/uploads/2025/08/principal-rfq-hub-digital-asset-derivatives-liquidity-aggregation.jpg)

## Best Execution Framework

Meaning ▴ The Best Execution Framework defines a structured methodology for achieving the most advantageous outcome for client orders, considering price, cost, speed, likelihood of execution and settlement, order size, and any other relevant considerations. </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 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)

## 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/order-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, futuristic institutional-grade instrument, representing high-fidelity execution of digital asset derivatives. Its sharp point signifies price discovery via RFQ protocols](https://options.greeks.live/wp-content/uploads/2025/07/precision-rfq-execution-engine-for-institutional-digital-asset-derivatives.jpg)

## Order Execution

Meaning ▴ Order Execution defines the precise operational sequence that transforms a Principal's trading intent into a definitive, completed transaction within a digital asset market. </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 meticulously engineered mechanism showcases a blue and grey striped block, representing a structured digital asset derivative, precisely engaged by a metallic tool. This setup illustrates high-fidelity execution within a controlled RFQ environment, optimizing block trade settlement and managing counterparty risk through robust market microstructure](https://options.greeks.live/wp-content/uploads/2025/08/precision-engineered-institutional-digital-asset-derivatives-rfq-execution.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:** [Order Execution Policy](https://options.greeks.live/area/order-execution-policy/), [RTS 27](https://options.greeks.live/area/rts-27/), [Regulatory Reporting](https://options.greeks.live/area/regulatory-reporting/), [Best Execution](https://options.greeks.live/area/best-execution/), [Market Microstructure](https://options.greeks.live/area/market-microstructure/), [Best Execution Framework](https://options.greeks.live/area/best-execution-framework/)	

## Discover More

- 
### [How Do Regulators Use Rts 27 and Rts 28 Reports to Oversee Best Execution?](https://options.greeks.live/question/how-do-regulators-use-rts-27-and-rts-28-reports-to-oversee-best-execution/)
![A sophisticated institutional-grade system's internal mechanics. A central metallic wheel, symbolizing an algorithmic trading engine, sits above glossy surfaces with luminous data pathways and execution triggers. This abstract visualizes high-fidelity execution for digital asset derivatives, optimizing market microstructure and RFQ protocol efficiency within a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine-core.jpg)

Regulators use RTS 27/28 data to benchmark execution quality, but now focus on auditing a firm's internal policies and TCA data directly.

- 
### [How Do Firms Use RTS 27 and RTS 28 Data to Prove Best Execution Compliance?](https://options.greeks.live/question/how-do-firms-use-rts-27-and-rts-28-data-to-prove-best-execution-compliance/)
![An abstract, precisely engineered construct of interlocking grey and cream panels, featuring a teal display and control. This represents an institutional-grade Crypto Derivatives OS for RFQ protocols, enabling high-fidelity execution, liquidity aggregation, and market microstructure optimization within a Principal's operational framework for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/08/integrated-principal-trading-system-modules-for-institutional-digital-asset-derivatives-rfq-execution-and-optimized-market-microstructure.jpg)

Firms use RTS 27 venue data and RTS 28 routing disclosures to build a quantitative, evidence-based system proving best execution compliance.

- 
### [How Does MiFID II’s Best Execution Standard Affect Non-Equity Asset Classes?](https://options.greeks.live/question/how-does-mifid-iis-best-execution-standard-affect-non-equity-asset-classes/)
![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. A visible sensor highlights market microstructure insights and price discovery.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-engine-digital-asset-derivatives-execution.jpg)

MiFID II's best execution standard mandates a data-driven, multi-factor approach to trading non-equity assets, enhancing transparency.

- 
### [How Does MiFID II Define Best Execution for Asset Managers?](https://options.greeks.live/question/how-does-mifid-ii-define-best-execution-for-asset-managers/)
![A sleek, institutional-grade device, with a glowing indicator, represents a Prime RFQ terminal. Its angled posture signifies focused RFQ inquiry for Digital Asset Derivatives, enabling high-fidelity execution and precise price discovery within complex market microstructure, optimizing latent liquidity.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-execution-terminal-facilitating-high-fidelity-price-discovery-and-optimal-liquidity-aggregation.jpg)

MiFID II defines best execution as a demonstrable system for achieving the optimal result based on price, cost, speed, and likelihood.

- 
### [How Did MiFID II’s Best Execution Standard Change the Requirements for Documenting Trades?](https://options.greeks.live/question/how-did-mifid-iis-best-execution-standard-change-the-requirements-for-documenting-trades/)
![Precision metallic mechanism with a central translucent sphere, embodying institutional RFQ protocols for digital asset derivatives. This core represents high-fidelity execution within a Prime RFQ, optimizing price discovery and liquidity aggregation for block trades, ensuring capital efficiency and atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-prime-os-execution-hub.jpg)

MiFID II transformed best execution from a qualitative obligation into a quantitative, data-driven mandate for provable performance.

- 
### [How Do Best Execution Requirements for Otfs Compare to Those for Sls and Mtfs?](https://options.greeks.live/question/how-do-best-execution-requirements-for-otfs-compare-to-those-for-sls-and-mtfs/)
![A modular, dark-toned system with light structural components and a bright turquoise indicator, representing a sophisticated Crypto Derivatives OS for institutional-grade RFQ protocols. It signifies private quotation channels for block trades, enabling high-fidelity execution and price discovery through aggregated inquiry, minimizing slippage and information leakage within dark liquidity pools.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-system-for-optimal-execution-1.jpg)

Best execution mandates a tailored approach, shifting from venue selection for MTFs to direct operator accountability for OTFs and SIs.

- 
### [What Are the Key Differences between MiFID II and Regulation NMS regarding Best Execution?](https://options.greeks.live/question/what-are-the-key-differences-between-mifid-ii-and-regulation-nms-regarding-best-execution/)
![Stacked precision-engineered circular components, varying in size and color, rest on a cylindrical base. This modular assembly symbolizes a robust Crypto Derivatives OS architecture, enabling high-fidelity execution for institutional RFQ protocols. It embodies layered liquidity aggregation, optimized price discovery within market microstructure, and capital efficiency for digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-protocol-architecture-optimized-for-high-fidelity-execution.jpg)

MiFID II mandates a holistic, principles-based approach to best execution, while Regulation NMS prioritizes a rules-based, price-centric framework.

- 
### [How Does MiFID II Influence RFQ Data Governance and Best Execution Requirements?](https://options.greeks.live/question/how-does-mifid-ii-influence-rfq-data-governance-and-best-execution-requirements/)
![A sleek, metallic mechanism symbolizes an advanced institutional trading system. The central sphere represents aggregated liquidity and precise price discovery. Its metallic arm signifies an algorithmic trading engine, facilitating high-fidelity execution for digital asset derivatives, with intricate base circuitry depicting optimized RFQ protocols and robust market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine-for-optimal-price-discovery-and-best-execution.jpg)

MiFID II mandates that RFQ protocols evolve into fully auditable, data-driven systems to prove best execution for clients.

- 
### [What Are the Regulatory Requirements for Demonstrating Best Execution in Europe and the US?](https://options.greeks.live/question/what-are-the-regulatory-requirements-for-demonstrating-best-execution-in-europe-and-the-us/)
![A spherical, eye-like structure, an Institutional Prime RFQ, projects a sharp, focused beam. This visualizes high-fidelity execution via RFQ protocols for digital asset derivatives, enabling block trades and multi-leg spreads with capital efficiency and best execution across market microstructure.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-prime-os-rfq-protocol-digital-asset-derivatives-block-trade-execution.jpg)

A firm's best execution capability is a direct reflection of its commitment to client alignment and operational excellence.

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---

**Original URL:** https://options.greeks.live/question/what-are-the-practical-challenges-of-complying-with-mifid-iis-best-execution-requirements/
