FIRDS Data Analysis on Day 1 of MiFID II

What information has FIRDS data provided on Day 1 of MiFID II?

I have provided some statistics on the use of the OTC-ISIN for regulatory reporting. In particular, who is using the OTC-ISINs, how many OTC-ISINs are they using and are they trading venues or systematic internalisers?

Some very large disclaimers first: This is our first pass. It is draft. It is only for 3rd Jan. It excludes any submissions from reporting entities before 3rd Jan.

Summary Analysis

With those disclaimers out of the way, here is our analysis of the FIRDS data.

  • 13 separate trading venues and systematic internalisers (at the segment MIC level) submitted a total of 258,973 OTC-ISIN records consisting of 130,200 unique ISINs
  • This represents 41% of total records and 30% of all unique instruments submitted to FIRDS
  • Trading venues represented 99.4% of all OTC-ISIN submissions and 12 out of the 13 entities (at the segment level) with Systematic Internalisers representing the rest

The Data


  • The DSB created 132,255 OTC-ISINs on day 1 of MiFID – see this article for more details and a 130,200 unique OTC-ISINs were submitted to FIRDS
  • EBS single-handedly was responsible for almost 99% of all OTC-ISIN submissions (and both EBS entities reported exactly the same set of OTC-ISINs)
  • Many large trading venues are completely absent from this list
  • GS is first off the blocks with Systematic Internaliser reporting


These statistics are sufficiently interesting that it would be great if others could validate our observations!

What information has FIRDS data provided after Week 1 of…

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