# What Are the Regulatory Implications under Mifid Ii for Reporting Trades Executed via Rfq? ▴ Question

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

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## Concept

The architecture of the Markets in Financial Instruments Directive II (MiFID II) establishes a dual-layered reporting framework for trades executed via a Request for Quote (RFQ) protocol. This framework is built upon two distinct pillars ▴ [post-trade transparency](https://prime.greeks.live/area/post-trade-transparency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) and [transaction reporting](https://prime.greeks.live/area/transaction-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). Post-trade transparency serves the public function of market integrity, requiring the near real-time disclosure of trade details to the wider market. Transaction reporting serves a supervisory function, mandating the submission of granular trade data directly to national competent authorities (NCAs) for market abuse monitoring.

Understanding the interplay between the RFQ execution method and these two [reporting obligations](https://prime.greeks.live/question/what-are-the-key-differences-in-reporting-obligations-between-a-systematic-internaliser-and-an-mtf/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is fundamental to designing a compliant operational workflow. The RFQ mechanism, a bilateral price discovery process, operates within a regulatory system that demands specific levels of disclosure, creating a point of tension between discreet liquidity sourcing and mandated transparency.

At its core, the regulatory treatment hinges on the classification of the entities involved and the venue of execution. An investment firm executing client orders on a frequent and substantial basis may qualify as a [Systematic Internaliser](https://prime.greeks.live/area/systematic-internaliser/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (SI). This classification carries with it direct post-trade reporting obligations. When an RFQ trade is conducted with an SI, the responsibility for making the trade public via an [Approved Publication Arrangement](https://prime.greeks.live/area/approved-publication-arrangement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (APA) falls squarely on the SI.

This design ensures that even off-venue, bilateral transactions contribute to the public data stream. Conversely, if the trade is executed on a regulated trading venue, such as a Multilateral Trading Facility (MTF) or an [Organised Trading Facility](https://prime.greeks.live/area/organised-trading-facility/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (OTF), the reporting obligation shifts to the venue operator itself. The system is architected to ensure a single point of publication, preventing duplicative reporting while guaranteeing that the data enters the public domain.

> The regulatory system under MiFID II assigns a single, unambiguous reporting entity for every trade to ensure data integrity and prevent redundancy.

The second pillar, transaction reporting under Regulatory Technical Standard (RTS) 22, operates in parallel but serves a different master. All investment firms that execute transactions in financial instruments are required to report comprehensive details of these trades to their national regulator by the close of the following working day (T+1). This obligation is exhaustive and applies regardless of whether the trade was executed on a venue or over-the-counter (OTC) with an SI. The data submitted to the regulator through an [Approved Reporting Mechanism](https://prime.greeks.live/area/approved-reporting-mechanism/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (ARM) is significantly more detailed than the public post-trade report.

It includes information identifying the client, the decision-maker for the trade, and specific flags that contextualize the execution, such as those indicating a trade was part of an RFQ process. This supervisory data stream provides regulators with the tools to reconstruct market activity and detect potential instances of insider dealing or market manipulation.

The RFQ protocol itself introduces specific considerations within this framework. Pre-trade transparency rules, for instance, generally require the publication of quotes. However, MiFID II provides for waivers for RFQ systems, recognizing that broadcasting requests to the entire market would undermine the targeted nature of the protocol. A trading venue can receive a waiver for its RFQ system, allowing firms to solicit quotes from a select number of counterparties without prior [public disclosure](https://prime.greeks.live/area/public-disclosure/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

This maintains the efficiency of the RFQ process for sourcing liquidity in specific, often less liquid, instruments. Nevertheless, once executed, the resulting trade is fully subject to post-trade transparency and transaction reporting rules, completing the cycle from discreet inquiry to regulated disclosure.

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## Strategy

Developing a strategic approach to MiFID II reporting for RFQ-executed trades requires a firm to analyze its operational structure, its trading patterns, and its desired market posture. The primary strategic decision point is whether to opt-in or become designated as a Systematic Internaliser. This choice has profound consequences for a firm’s reporting infrastructure, counterparty relationships, and overall operational complexity. Operating as an SI centralizes post-trade reporting responsibility, which can be positioned as a service to clients who are then absolved of the public disclosure duty for trades executed with the SI.

This can be a competitive advantage, simplifying the operational burden for counterparties. The SI regime, however, necessitates the establishment of robust systems for identifying reportable trades, enriching them with the correct data, and transmitting them to an APA within the prescribed timeframes, which can be as short as near real-time.

A secondary strategic layer involves the choice of execution venue and methodology. Firms have a choice between executing [RFQ trades](https://prime.greeks.live/area/rfq-trades/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) bilaterally with an SI, or conducting them on an OTF or MTF. Each path presents a different allocation of reporting duties and strategic trade-offs. Executing on a venue offloads the post-trade transparency obligation to the venue operator, which can be an attractive proposition for firms wishing to minimize their [public reporting](https://prime.greeks.live/question/what-are-the-key-differences-in-reporting-requirements-between-public-post-trade-transparency-and-regulatory-transaction-reporting-for-lis-orders/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) infrastructure.

This path, however, may involve different fee structures and a potentially wider set of counterparties responding to the request, altering the information footprint of the trade. The strategic calculus involves weighing the operational simplicity of venue-based execution against the potential for greater discretion and tailored liquidity access in a bilateral SI relationship. A sophisticated strategy might involve a hybrid approach, directing different types of RFQ flow to different venues or SIs based on the asset class, trade size, and the desired level of information control.

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## How Does Trade Size Influence Reporting Strategy?

The MiFID II framework incorporates specific thresholds that are central to any reporting strategy, particularly for RFQ trades which are often used for larger orders. The concepts of Large-in-Scale (LIS) and Size-Specific-to-the-Instrument (SSTI) provide mechanisms for delaying the public disclosure of a trade. A core strategic objective for institutional traders is to minimize market impact, and the ability to defer reporting is a critical tool in this endeavor. A trade that qualifies as LIS can have its publication deferred for an extended period, allowing the firm to complete its trading activity without immediately alerting the market to its full size and direction.

The strategy, therefore, must involve systems capable of classifying each trade against the LIS/SSTI thresholds for the specific instrument being traded. These thresholds are not static; they are calculated and published periodically by regulators. An effective strategy requires dynamic monitoring of these thresholds and integrating them into pre-trade decision-making and post-trade processing workflows. This allows a firm to systematically leverage deferrals where permissible, aligning its regulatory obligations with its core goal of achieving [best execution](https://prime.greeks.live/area/best-execution/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

> A firm’s ability to classify trades against LIS thresholds in real-time is a key determinant of its capacity to manage market impact effectively.

The table below outlines the strategic implications of different execution choices on the allocation of reporting responsibilities. This clarifies the operational pathways and the entities accountable for fulfilling MiFID II’s transparency and supervisory mandates.

### Allocation of MiFID II Reporting Obligations for RFQ Trades

| Execution Scenario | Responsible Party for Post-Trade Transparency (Public Report to APA) | Responsible Party for Transaction Reporting (Supervisory Report to NCA) | Key Strategic Consideration |
| --- | --- | --- | --- |
| Bilateral RFQ with a Systematic Internaliser (SI) | The Systematic Internaliser | Both the SI and its counterparty (if a MiFID investment firm) | The SI takes on the public reporting burden, offering an operational simplification for its clients. The client firm must still handle its own private transaction report. |
| RFQ on an Organised Trading Facility (OTF) | The OTF Operator | Both counterparties to the trade (the executing investment firms) | Offloads the complexity of real-time public reporting to a third-party venue, but requires robust internal systems for the T+1 supervisory report. |
| Bilateral RFQ (neither party is an SI) | The selling investment firm | Both the selling and buying investment firms | This scenario places the highest operational burden on the selling firm, which must have the systems in place to act as the reporting party. It is often a less desirable strategic path. |
| RFQ with a non-EU counterparty | The EU investment firm | The EU investment firm | The EU firm bears the full MiFID II reporting responsibility, requiring systems that can identify the status of counterparties and adjust reporting logic accordingly. |

Ultimately, the strategy for managing RFQ reporting under MiFID II is one of systemic integration. It requires the seamless connection of front-office execution platforms, middle-office trade confirmation and enrichment systems, and back-office reporting gateways. Data must flow efficiently through this chain, with each trade being correctly identified, classified, and routed to the appropriate reporting channel ▴ be it an APA for public transparency or an ARM for supervisory oversight.

The architecture must be designed for accuracy and timeliness, as reporting failures can lead to significant regulatory penalties and reputational damage. The optimal strategy is one that transforms the regulatory requirements from a mere compliance burden into a component of a well-engineered and efficient trading apparatus.

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## Execution

The execution of MiFID II reporting for RFQ trades is a matter of precise operational engineering. It requires the configuration of systems and processes to capture, enrich, and transmit trade data in accordance with strict regulatory timelines and formats. The entire workflow can be deconstructed into two parallel but distinct operational streams ▴ the process for post-trade transparency reporting to the public and the process for transaction reporting to regulators.

Each stream has its own designated reporting channel, data requirements, and logic for determining the responsible reporting entity. A failure in any part of this operational chain can result in incomplete, inaccurate, or late reports, triggering regulatory scrutiny.

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## The Operational Playbook for Post-Trade Transparency

The public reporting of an [RFQ trade](https://prime.greeks.live/area/rfq-trade/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) must be executed as close to real-time as technically possible. For a firm acting as a Systematic Internaliser, this means having a direct, low-latency connection to an Approved Publication Arrangement. The operational playbook involves a series of automated steps that must be executed flawlessly for every relevant trade.

- 
**Trade Capture** ▴ The moment an RFQ is accepted and a trade is executed, the core details of the transaction must be captured by the firm’s trade management system. This includes the instrument identifier (ISIN), price, quantity, and execution timestamp.

- 
**Enrichment and Classification** ▴ The captured trade data is immediately enriched with additional information. The system must determine if the trade qualifies for a reporting deferral by comparing its size to the Large-in-Scale (LIS) threshold for that specific financial instrument. This is a critical step that dictates the timing of the report.

- 
**Report Generation** ▴ Based on the enriched data, a post-trade transparency report is generated in the format prescribed by the APA. This report contains a subset of the full trade details, focusing on the information relevant to the public.

- 
**Transmission** ▴ The generated report is transmitted to the APA. The system must handle acknowledgments and potential rejections from the APA, with clear protocols for error handling and re-submission.

- 
**Monitoring and Reconciliation** ▴ The firm’s operations team must have a dashboard to monitor the status of all reports sent to the APA, reconciling them against internal trade logs to ensure that every reportable trade has been successfully published.

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## The Operational Playbook for RTS 22 Transaction Reporting

The T+1 [transaction report](https://prime.greeks.live/question/what-are-the-primary-points-of-failure-in-the-order-to-transaction-report-lifecycle/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is a more detailed and complex undertaking. It provides a complete picture of the trade for supervisory purposes. The execution of this report is a separate, though related, workflow.

- 
**Data Aggregation** ▴ By the end of the trading day, all executed trades are aggregated. The system must pull in a much wider set of data fields for each trade, including sensitive information not intended for public disclosure.

- 
**Comprehensive Enrichment** ▴ This is the most data-intensive step. The system must enrich the trade record with a multitude of identifiers and flags required by [RTS 22](https://prime.greeks.live/area/rts-22/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). This includes the [Legal Entity Identifier](https://prime.greeks.live/area/legal-entity-identifier/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) (LEI) of the client, the person or algorithm responsible for the investment decision, and flags indicating the nature of the trade, such as whether it was a short sale or executed under an RFQ protocol.

- 
**Report Formatting and Validation** ▴ A transaction report, typically in XML format, is constructed for each trade. This report must be validated against the RTS 22 schema to ensure it is correctly formatted and contains all mandatory fields before submission.

- 
**Submission to ARM** ▴ The validated reports are submitted in a batch file to an Approved Reporting Mechanism, which acts as a conduit to the national competent authority.

- 
**Feedback Processing** ▴ The ARM will provide feedback files indicating the status of each submitted report (e.g. accepted, rejected). The operational team must have a robust process for analyzing rejections, identifying the root cause of the error, correcting the data, and resubmitting the report in a timely manner.

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## What Are the Specific Data Fields for an RFQ Transaction Report?

The level of detail required for an RTS 22 transaction report is substantial. The table below provides a sample of the key data fields that must be populated for a typical RFQ trade in a corporate bond, illustrating the granularity of the information required by regulators. This data provides a forensic trail for every transaction.

### Sample RTS 22 Transaction Report Fields for a Corporate Bond RFQ Trade

| Field Number | Field Name | Example Value | Operational Purpose and Context |
| --- | --- | --- | --- |
| 1 | Reporting firm LEI | 549300L3W8G2I4X6Y789 | Identifies the investment firm submitting the report. This is a foundational field for assigning accountability. |
| 4 | Buyer identification code | 213800A3B4C5D6E7F890 | The Legal Entity Identifier of the counterparty purchasing the instrument. Essential for reconstructing the trade. |
| 11 | Seller identification code | 549300L3W8G2I4X6Y789 | The Legal Entity Identifier of the counterparty selling the instrument. In this case, it is the reporting firm. |
| 28 | Trading date and time | 2025-08-05T14:32:17Z | The precise moment the trade was executed, recorded in Coordinated Universal Time (UTC). Critical for market abuse analysis. |
| 30 | Trading capacity | DEAL | Indicates the firm was dealing on its own account. Other values include ‘AOTC’ (any other capacity). |
| 33 | Quantity | 5000000 | The nominal value of the bond transaction. |
| 34 | Price | 101.25 | The clean price at which the trade was executed, expressed as a percentage of the nominal value. |
| 44 | Instrument identification code | DE000A1G3J42 | The International Securities Identification Number (ISIN) of the bond that was traded. This is the primary identifier for the financial instrument. |
| 57 | Investment decision within firm | 987654321098765432 | A unique national identifier for the person or a code for the algorithm at the firm responsible for the decision to trade. |
| 61 | Execution within firm | ALGO007 | A code identifying the algorithm responsible for the execution of the trade. If a human trader executed it, their national identifier would be used. |
| 65 | Trading venue transaction identification code | OTF_RFQ_TRD_987654 | If executed on a venue, this is the unique code assigned by the venue. For bilateral SI trades, this field may not be populated. |

> The successful execution of MiFID II reporting hinges on the firm’s ability to maintain and access a comprehensive and accurate repository of client, counterparty, and internal decision-maker data.

The technological architecture supporting these workflows is paramount. It requires a central data repository, often called a “trade store” or “data lake,” where all raw trade information is held. This repository is fed by the firm’s Order Management System (OMS) and Execution Management System (EMS).

A dedicated reporting engine then pulls data from this store, applies the necessary enrichment and validation rules, and communicates with the APAs and ARMs via secure APIs. The entire system must be resilient, with built-in redundancy and failover capabilities, to ensure that the firm can meet its reporting obligations without interruption, even in the face of technical issues or high trading volumes.

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## References

- European Securities and Markets Authority. “Guidelines on transaction reporting, order record keeping and clock synchronisation.” ESMA/2016/1452, 10 October 2016.

- European Commission. “Commission Delegated Regulation (EU) 2017/590 of 28 July 2016 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards for the reporting of transactions to competent authorities.” Official Journal of the European Union, L 87, 31 March 2017.

- International Capital Market Association. “MiFID II/R implementation ▴ A guide for the fixed income markets.” September 2017.

- AFME. “MiFID II / MiFIR post-trade reporting requirements.” October 2017.

- Luxembourg Stock Exchange. “MiFID II & MiFIR Technical Standards.” 2018.

- Electronic Debt Markets Association. “Consultation Paper on the Review of RTS 22 on transaction data reporting under Art. 26 and RTS 24 on order book data to be maintained under Art. 25 of MiFIR.” 17 January 2025.

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

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

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## Reflection

The intricate web of reporting obligations under MiFID II for RFQ-executed trades presents a significant architectural challenge for any [investment firm](https://prime.greeks.live/area/investment-firm/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite). The regulations transform the simple act of a trade into a complex data-generating event that must be managed with precision and foresight. The dual streams of public transparency and supervisory reporting demand a holistic view of a firm’s data infrastructure. It prompts a fundamental question ▴ is your firm’s operational architecture designed as a cohesive system for managing regulatory data, or is it a collection of disparate processes bolted together as a reaction to compliance mandates?

Viewing these requirements through a systems architecture lens reveals their true nature. They are specifications for a data processing machine. The quality of the output of this machine ▴ the accuracy, timeliness, and completeness of its reports ▴ is a direct reflection of the quality of its design. A well-architected system not only ensures compliance but also generates valuable internal data.

The process of gathering and structuring data for regulatory reporting can be leveraged to create a richer internal understanding of execution quality, counterparty behavior, and information leakage. The regulatory mandate, therefore, can be a catalyst for building a more intelligent and self-aware trading enterprise.

Ultimately, the mastery of these reporting protocols is a component of a larger operational capability. It is about building a framework that can absorb and adapt to complex regulatory inputs without compromising execution efficiency. The challenge lies in designing systems that are both robust enough to ensure compliance today and flexible enough to adapt to the inevitable evolution of regulation tomorrow. The firm that achieves this has built more than a compliance engine; it has constructed a durable strategic asset.

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## Glossary

<a href="https://prime.greeks.live/area/post-trade-transparency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Post-Trade Transparency

Meaning ▴ Post-Trade Transparency defines the public disclosure of executed transaction details, encompassing price, volume, and timestamp, after a trade has been completed. </a><a href="https://prime.greeks.live/area/transaction-reporting/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated, angular digital asset derivatives execution engine with glowing circuit traces and an integrated chip rests on a textured platform. This symbolizes advanced RFQ protocols, high-fidelity execution, and the robust Principal's operational framework supporting institutional-grade market microstructure and optimized liquidity aggregation](https://options.greeks.live/wp-content/uploads/2025/08/advanced-digital-asset-derivatives-rfq-protocol-engine-architecture.jpg)

## Transaction Reporting

Meaning ▴ Transaction Reporting defines the formal process of submitting granular trade data, encompassing execution specifics and counterparty information, to designated regulatory authorities or internal oversight frameworks. </a><a href="https://prime.greeks.live/question/what-are-the-key-differences-in-reporting-obligations-between-a-systematic-internaliser-and-an-mtf/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sophisticated mechanism depicting the high-fidelity execution of institutional digital asset derivatives. It visualizes RFQ protocol efficiency, real-time liquidity aggregation, and atomic settlement within a prime brokerage framework, optimizing market microstructure for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-rfq-protocol-execution-liquidity-aggregation-system.jpg)

## Reporting Obligations

An MTF's reporting is a centralized broadcast of multilateral activity, while an SI's is a mandatory disclosure of its bilateral, principal trades. </a><a href="https://prime.greeks.live/area/approved-publication-arrangement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A dark, textured module with a glossy top and silver button, featuring active RFQ protocol status indicators. This represents a Principal's operational framework for high-fidelity execution of institutional digital asset derivatives, optimizing atomic settlement and capital efficiency within market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-interface-1.jpg)

## Approved Publication Arrangement

Meaning ▴ An Approved Publication Arrangement (APA) is a regulated entity authorized to publicly disseminate post-trade transparency data for financial instruments, as mandated by regulations such as MiFID II and MiFIR. </a><a href="https://prime.greeks.live/area/systematic-internaliser/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered system with a central gnomon-like structure and suspended sphere. This signifies high-fidelity execution for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/precision-engine-for-institutional-digital-asset-derivatives-rfq.jpg)

## Systematic Internaliser

Meaning ▴ A Systematic Internaliser (SI) is a financial institution executing client orders against its own capital on an organized, frequent, systematic basis off-exchange. </a><a href="https://prime.greeks.live/area/organised-trading-facility/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Organised Trading Facility

Meaning ▴ An Organised Trading Facility (OTF) represents a specific type of multilateral system, as defined under MiFID II, designed for the trading of non-equity instruments. </a><a href="https://prime.greeks.live/area/approved-reporting-mechanism/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
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## Approved Reporting Mechanism

Meaning ▴ Approved Reporting Mechanism (ARM) denotes a regulated entity authorized to collect, validate, and submit transaction reports to competent authorities on behalf of investment firms. </a><a href="https://prime.greeks.live/area/public-disclosure/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A beige, triangular device with a dark, reflective display and dual front apertures. This specialized hardware facilitates institutional RFQ protocols for digital asset derivatives, enabling high-fidelity execution, market microstructure analysis, optimal price discovery, capital efficiency, block trades, and portfolio margin](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-terminal-for-high-fidelity-execution-and-precise-market-microstructure-analysis.jpg)

## Public Disclosure

Meaning ▴ Public disclosure is the mandated or voluntary dissemination of material information to the market, ensuring transparency and equitable access. </a><a href="https://prime.greeks.live/question/what-are-the-key-differences-in-reporting-requirements-between-public-post-trade-transparency-and-regulatory-transaction-reporting-for-lis-orders/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An institutional-grade RFQ Protocol engine, with dual probes, symbolizes precise price discovery and high-fidelity execution. This robust system optimizes market microstructure for digital asset derivatives, ensuring minimal latency and best execution](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-engine-for-optimal-price-discovery-and-high-fidelity-execution.jpg)

## Public Reporting

The two reporting streams for LIS orders are architected for different ends ▴ public transparency for market price discovery and regulatory reporting for confidential oversight. </a><a href="https://prime.greeks.live/area/rfq-trades/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, black and beige institutional-grade device, featuring a prominent optical lens for real-time market microstructure analysis and an open modular port. This RFQ protocol engine facilitates high-fidelity execution of multi-leg spreads, optimizing price discovery for digital asset derivatives and accessing latent liquidity](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-execution-engine-for-high-fidelity-price-discovery-and-latent-liquidity-aggregation-across-multi-leg-spreads.jpg)

## Rfq Trades

Meaning ▴ RFQ Trades, or Request for Quote Trades, represents a structured, bilateral or multilateral negotiation protocol employed by institutional participants to solicit price indications for specific financial instruments, typically off-exchange. </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, 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)

## 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/rfq-trade/?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)

## Rfq Trade

Meaning ▴ An RFQ Trade, or Request for Quote Trade, represents a structured, off-exchange execution protocol where a liquidity-seeking entity solicits firm price quotes for a specific financial instrument, often a block of digital asset derivatives, from a selected group of liquidity providers. </a><a href="https://prime.greeks.live/question/what-are-the-primary-points-of-failure-in-the-order-to-transaction-report-lifecycle/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Intricate metallic components signify system precision engineering. These structured elements symbolize institutional-grade infrastructure for high-fidelity execution of digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-precision-engineering-for-high-fidelity-execution-and-latency-optimization.jpg)

## Transaction Report

The primary points of failure in the order-to-transaction report lifecycle are data fragmentation, system vulnerabilities, and process gaps. </a><a href="https://prime.greeks.live/area/legal-entity-identifier/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precise, multi-layered disk embodies a dynamic Volatility Surface or deep Liquidity Pool for Digital Asset Derivatives. Dual metallic probes symbolize Algorithmic Trading and RFQ protocol inquiries, driving Price Discovery and High-Fidelity Execution of Multi-Leg Spreads within a Principal's operational framework](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-rfq-protocol-mechanism-for-digital-asset-derivatives-price-discovery-and-high-fidelity-execution-via-prime-os.jpg)

## Legal Entity Identifier

Meaning ▴ The Legal Entity Identifier is a 20-character alphanumeric code uniquely identifying legally distinct entities in financial transactions. </a><a href="https://prime.greeks.live/area/rts-22/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A precision-engineered institutional digital asset derivatives execution system cutaway. The teal Prime RFQ casing reveals intricate market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-rfq-protocol-core-engine.jpg)

## Rts 22

Meaning ▴ RTS 22 mandates the comprehensive recording of all relevant telephone conversations and electronic communications for firms conducting MiFID activities, establishing a verifiable audit trail for regulatory oversight and market integrity. </a><a href="https://prime.greeks.live/area/investment-firm/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, precision-engineered device with a split-screen interface displaying implied volatility and price discovery data for digital asset derivatives. This institutional grade module optimizes RFQ protocols, ensuring high-fidelity execution and capital efficiency within market microstructure for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-module.jpg)

## Investment Firm

Meaning ▴ An Investment Firm constitutes a regulated financial entity primarily engaged in the management, trading, and intermediation of financial instruments on behalf of institutional clients or for its own proprietary account. </a>

**Tags:** [Systematic Internaliser](https://options.greeks.live/area/systematic-internaliser/), [Investment Firm](https://options.greeks.live/area/investment-firm/), [Large-in-Scale Deferral](https://options.greeks.live/area/large-in-scale-deferral/), [Public Disclosure](https://options.greeks.live/area/public-disclosure/), [Post-Trade Transparency](https://options.greeks.live/area/post-trade-transparency/), [Transaction Reporting](https://options.greeks.live/area/transaction-reporting/)	

## Discover More

- 
### [What Are the Primary Regulatory Differences between Rfq and Clob under MiFID II?](https://options.greeks.live/question/what-are-the-primary-regulatory-differences-between-rfq-and-clob-under-mifid-ii/)
![Sleek metallic structures with glowing apertures symbolize institutional RFQ protocols. These represent high-fidelity execution and price discovery across aggregated liquidity pools. A dark aperture suggests a dark pool, crucial for discreet block trade and multi-leg spread negotiation.](https://options.greeks.live/wp-content/uploads/2025/07/precision-digital-asset-derivatives-trading-systems-optimizing-rfq-protocols-for-institutional-block-trade-execution.jpg)

MiFID II mandates CLOBs for transparent price discovery while architecting RFQs with waivers for discreet, large-scale risk transfer.

- 
### [What Are the Specific Post-Trade Reporting Requirements for RFQ Trades under MiFID II?](https://options.greeks.live/question/what-are-the-specific-post-trade-reporting-requirements-for-rfq-trades-under-mifid-ii/)
![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. This visualizes institutional execution pathways, emphasizing atomic settlement and capital efficiency in digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-microstructure.jpg)

MiFID II mandates public reporting of RFQ trades via an APA to enhance market transparency, with specific rules for timing and deferrals.

- 
### [How Does MiFID II Impact Liquidity Discovery in RFQ Systems?](https://options.greeks.live/question/how-does-mifid-ii-impact-liquidity-discovery-in-rfq-systems/)
![An abstract, angular sculpture with reflective blades from a polished central hub atop a dark base. This embodies institutional digital asset derivatives trading, illustrating market microstructure, multi-leg spread execution, and high-fidelity execution. It represents price discovery via RFQ protocols, enabling atomic settlement through an advanced Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-price-discovery-system.jpg)

MiFID II transformed the RFQ protocol into a compliant, data-rich system for sourcing discreet liquidity.

- 
### [How Does the Role of an Approved Publication Arrangement Differ from That of a Traditional Exchange?](https://options.greeks.live/question/how-does-the-role-of-an-approved-publication-arrangement-differ-from-that-of-a-traditional-exchange/)
![A sleek, conical precision instrument, with a vibrant mint-green tip and a robust grey base, represents the cutting-edge of institutional digital asset derivatives trading. Its sharp point signifies price discovery and best execution within complex market microstructure, powered by RFQ protocols for dark liquidity access and capital efficiency in atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-microstructure-price-discovery-optimization-prime-os-intelligence-layer.jpg)

An exchange is a venue for centralized trade execution, whereas an APA is a service for the public reporting of decentralized, off-venue trades.

- 
### [What Are the Core Technological Requirements for Effectively Using RFQ Protocols under MiFID II?](https://options.greeks.live/question/what-are-the-core-technological-requirements-for-effectively-using-rfq-protocols-under-mifid-ii/)
![A multi-layered, circular device with a central concentric lens. It symbolizes an RFQ engine for precision price discovery and high-fidelity execution. This robust system enables institutional digital asset derivatives trading, reflecting advanced market microstructure, volatility surface analysis, Principal's operational framework, and efficient options trading.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-for-precision-execution.jpg)

A MiFID II RFQ system is an architectural solution for evidencing best execution through integrated data, connectivity, and reporting.

- 
### [In What Ways Does the Regulatory Environment, Such as Mifid Ii, Impact the Use of Rfq Protocols for Institutional Trading?](https://options.greeks.live/question/in-what-ways-does-the-regulatory-environment-such-as-mifid-ii-impact-the-use-of-rfq-protocols-for-institutional-trading/)
![A precision metallic instrument with a black sphere rests on a multi-layered platform. This symbolizes institutional digital asset derivatives market microstructure, enabling high-fidelity execution and optimal price discovery across diverse liquidity pools. Essential for managing counterparty risk and multi-leg spread strategies within the Prime RFQ protocol intelligence layer.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-engine-component-digital-asset-derivatives-market-microstructure.jpg)

MiFID II integrates RFQ protocols into a transparent, data-driven framework, mandating auditable best execution and systemic reporting.

- 
### [What Are the Key Differences in Record-Keeping for RFQ versus Lit Order Books?](https://options.greeks.live/question/what-are-the-key-differences-in-record-keeping-for-rfq-versus-lit-order-books/)
![A sharp, metallic blue instrument with a precise tip rests on a light surface, suggesting pinpoint price discovery within market microstructure. This visualizes high-fidelity execution of digital asset derivatives, highlighting RFQ protocol efficiency. It represents the intelligence layer of a Prime RFQ for atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/07/precision-digital-asset-derivative-rfq-execution-market-microstructure-high-fidelity-alpha-generation-prime-os-system.jpg)

The key difference in record-keeping is documenting a public, sequential auction (Lit Book) versus a private, parallel negotiation (RFQ).

- 
### [How Does MiFID II Define a Systematic Internaliser?](https://options.greeks.live/question/how-does-mifid-ii-define-a-systematic-internaliser/)
![A sleek, multi-component device with a dark blue base and beige bands culminates in a sophisticated top mechanism. This precision instrument symbolizes a Crypto Derivatives OS facilitating RFQ protocol for block trade execution, ensuring high-fidelity execution and atomic settlement for institutional-grade digital asset derivatives across diverse liquidity pools.](https://options.greeks.live/wp-content/uploads/2025/08/advanced-mechanism-for-principal-trading-firm-rfq-protocols-and-high-fidelity-digital-asset-derivatives-execution.jpg)

A Systematic Internaliser is an investment firm that uses its own capital to execute client orders bilaterally within a regulated framework.

- 
### [How Do Regulatory Frameworks like MiFID II Influence the Adoption of Electronic RFQ Platforms?](https://options.greeks.live/question/how-do-regulatory-frameworks-like-mifid-ii-influence-the-adoption-of-electronic-rfq-platforms/)
![A solid object, symbolizing Principal execution via RFQ protocol, intersects a translucent counterpart representing algorithmic price discovery and institutional liquidity. This dynamic within a digital asset derivatives sphere depicts optimized market microstructure, ensuring high-fidelity execution and atomic settlement.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-microstructure-orchestration.jpg)

MiFID II mandates verifiable best execution, making data-rich electronic RFQ platforms the systemic solution for compliant liquidity sourcing.

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        {
            "@type": "Question",
            "name": "What Are The Specific Data Fields For An RFQ Transaction Report?",
            "acceptedAnswer": {
                "@type": "Answer",
                "text": "The level of detail required for an RTS 22 transaction report is substantial. The table below provides a sample of the key data fields that must be populated for a typical RFQ trade in a corporate bond, illustrating the granularity of the information required by regulators. This data provides a forensic trail for every transaction."
            }
        }
    ]
}
```


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**Original URL:** https://options.greeks.live/question/what-are-the-regulatory-implications-under-mifid-ii-for-reporting-trades-executed-via-rfq/
