As we edge ever-closer to January 2018, the finer details of MiFID II are yet to fully surface, particularly with regard to RTS 22 and the rules around transaction reporting – undeniably one of the larger pieces of the new regulation. There is still much
work to do when it comes to finalising the detailed requirements and the
Level 2 RTS are still not published in the Official Journal. While the next round of
consultations and Q&A is starting to emerge from ESMA, signalling progress, it does rather feel like that extra year for implementation is fast slipping away.