Post-trade Transparency

Post-trade transparency refers to the trading venue's obligations to publish the relevant data of each transaction immediately or, according to the venue's deferred publication regime, at the end of a defined time period.

While transactions that were carried out outside of normal business hours are to be published prior to the start of trading on the next trading day, deferred publication during a venue's trading hours may only be granted for transactions that:

  • are large in size (i.e. trades above standard market size as specified by security);
  • expose Liquidity Providers to unexceptional risk;
  • require the nature of counterparties (retail / wholesale investors) to be taken into account;
  • are carried out in illiquid securities.

Thresholds for large-in-size transactions as well as the classification of liquid/illiquid instruments are defined on an instrument-level (bonds) or for the whole asset class (equities and structured products).

Note for Remote Members of SIX Swiss Exchange / SIX Corporate Bonds:

Based on Art. 20 and 21 MiFIR EU investment firms have to make information on transactions in financial instruments traded on a trading venue (including third country trading venues) public through approved publication arrangements (APA).

ESMA will publish a list of third country trading venues that meet the criteria as well as a list of trading venues not meeting these criteria. Potentially due to the high number of applications ESMA published their updated opinion on 15th December 2017 (ESMA70-154-467) with the statement:
“in order to contribute to the smooth implementation of MiFID II/MiFIR as of 3 January 2018 and to maintain a level playing field between third country trading venues, transactions on third country trading venues should not be required to be made post-trade transparent under Articles 20 and 21 of MiFIR pending the publication of the outcome of the assessment of the criteria stated in paragraph 10.”

Related topics: Trade Flagging Obligation and Data Disaggregation

Our approach

SIX Swiss Exchange already features deferred publication regimes for each of its trading segments and services which in most cases shall be adapted to meet (or exceed) the new Swiss and European regulation.

SSX trading segments Deferred Publication (off-book trades only)
Equities / SFS Existing functionality, new ESMA delayed publication table (RTS 1 Annex II Table 4) to be applied
Sep.Trading Lines, Rights Immediate - no change
ETF / ETSF / ETP / SF Immediate - no change
IF No deferral of publication - no change (implemented already with SMR6 in Oct. 2016)
CHF Bonds
Deferral to T+1, 7 am possible if bond is illiquid or trade qualifies for Large in Scale or SSTI post-trade transparency waivers - new!
Non-CHF Bonds Deferral to T+2, 7 pm possible if bond is illiquid or trade qualifies for Large in Scale or SSTI post-trade transparency waivers - new!
Structured Products No deferral of publication - no change
Service / venue Deferred Publication
SLS No change - all trades published immediately
SCB Deferral to T+2, 7 pm possible if bond is illiquid or trade qualifies for Large in Scale waiver (qualification validated separately for corporate and benchmark trade) - new!
XBTR Under evaluation (publication of final FINMA circular on “Organised trading facilities" to be awaited)

We believe the approach outlined is fully compliant with Swiss law and aligned to the principles of EU law but is subject to regulatory approvals.

The abolition of deferred publication in the investment funds segment is scheduled for SMR6 (2016) while all other changes will be implemented with SMR7 (2017).

Swiss Regulation

European Regulation