The Markets in Financial Instruments Directive II and its accompanying regulation govern investment services across the EU — including pre- and post-trade transparency obligations, the unbundling of research from execution, best-execution reporting, and the requirement that trading venues make market data available on a reasonable commercial basis.
MiFID II
Directive European Union
MiFID II is the regime that turned market data from a by-product of trading into a regulated product in its own right. Alongside MiFIR it governs investment services across the EU, and three of its provisions shape what this catalog measures.
- Pre- and post-trade transparency - Trading venues and systematic internalisers must publish quotes and executed trades, within defined deferral regimes.
- Reasonable commercial basis - Venues must make that data available on a reasonable commercial basis and, after fifteen minutes, free of charge. What “reasonable” means has been contested since the day it commenced.
- Research unbundling - Investment research must be paid for separately from execution, which repriced a large part of the data and analytics market.
- Best execution reporting - Firms must evidence execution quality, which generates its own demand for reference and transaction data.
MiFID II is the clearest example in this catalog of a regime that compels publication without compelling an interface. Venues must make data available; nothing says it must be reachable through a documented, machine-readable contract, and the commercial terms attached to it — licensing, entitlement, redistribution control — are precisely what a self-serve API removes.
That tension shows up in the scores. The State of Market Data APIs found that in this sector the feed is the commodity and the operation is the moat, and that commercial clarity behaves unlike any other market in this research: pricing pages exist, but what they price is an entitlement rather than a call. A regime that made data a licensed product produced an industry whose contracts are negotiated, and negotiation is the one thing an agent cannot do.
Referenced in API Evangelist papers
This regulation shows up in my published research. These reports read the machine-readable evidence provider by provider — and put this regulation in the context of a real sector.
The State of Market Data APIs
The regime that made market data a licensed, entitled, redistribution-controlled product — and the reason commercial clarity behaves differently in this sector than anywhere else in the series.