What information has FIRDS data provided after Week 1 of MiFID II?

Last week, I provided some analysis on the entities that submitted RTS23 reference data for OTC-ISINs on day 1 of MiFID II. That analysis can be found on Linked-In here.

In this article, I have provided the same analysis based on the week 1 full snapshot FIRDS file released over the weekend. The figures continue to be very interesting.

Summary Analysis

  • 19 trading venues and systematic internalisers (at the segment MIC level) submitted 637,742 records consisting of 437,290 unique OTC-ISINs
  • Tradeweb numbers have exploded from 453 submissions on the first day to 251,224 over the three days, single-handedly supplying 39.4% of all OTC-ISIN records
  • EBS continues to lead in overall numbers with 56.9% of all OTC-ISIN submissions
  • Bloomberg, Tradition, Integral are the new kids on the trading venue block, between them providing 0.65% of submissions
  • Societe Generale joins Goldman Sachs within the small ranks of systematic internalisers, together contributing 2.21% of the OTC-ISIN record submissions

The Data


  • The discrepancy between Tradeweb numbers and Bloomberg numbers is noteworthy given their respective market shares in OTC derivative trading
  • Same observation between FX All and EBS submission numbers vs their FX market shares
  • The ToTV implications of large numbers of submissions by a couple of trading venues is interesting
  • While many FX venues are well represented in these figures, many large non-FX trading venues have so far made no valid submissions to FIRDS
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[…] blog updates my previous post after week 1 of MiFID II, to reveal a much more diverse and interesting universe of trading venues and systematic […]