MiFID Market Data Costs form the foundation of transparent cost structures and ensure comprehensive cost control through precise data cost analysis and regulatory transparency. As a leading AI consultancy, we develop customized RegTech solutions for intelligent cost management automation, optimized vendor relationships, and strategic Market Data Cost excellence with complete IP protection.
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Market data providers authorised before 23 November 2025 must align existing contractual arrangements with the new RTS requirements by 22 August 2026. ESMA withdrew its previous RCB guidelines in February 2026.
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We systematically analyse your market data landscape, review existing contracts for RCB compliance and develop a sustainable compliance strategy for the new ESMA requirements.
Phase 1: Inventory of all market data contracts, data sources and cost structures
Phase 2: RCB gap analysis – comparison of existing pricing models against Art. 13 MiFIR and ESMA RTS
Phase 3: Development of an unbundling concept and transparent cost allocation
Phase 4: Contract adjustment and renegotiation with market data providers
Phase 5: Ongoing monitoring of market data costs and Consolidated Tape integration
"The intelligent optimization of MiFID Market Data Costs is the key to sustainable cost efficiency and regulatory excellence. Our AI-supported cost transparency solutions enable institutions not only to achieve regulatory compliance but also to develop strategic efficiency advantages through automated cost analysis and predictive vendor management optimization. By combining deep Market Data Cost expertise with advanced AI technologies, we create sustainable competitive advantages while protecting sensitive cost data."

Head of Risk Management
We offer you tailored solutions for your digital transformation
We use advanced AI algorithms to optimize Market Data Cost analysis and develop automated systems for precise cost validation and real-time cost transparency.
Our AI platforms develop highly precise vendor management systems with automated cost allocation and continuous vendor performance monitoring.
We implement intelligent cost transparency systems with machine learning compliance monitoring for maximum reporting quality.
We develop intelligent systems for continuous cost analysis with predictive budgeting measures and automatic cost optimization.
Our AI platforms automate cross-vendor cost management with intelligent multi-provider compliance optimization and predictive vendor harmonization.
We accompany you in the intelligent transformation of your MiFID Market Data Cost compliance and the development of sustainable AI cost transparency capabilities.
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MiFID Algorithmic Trading defines comprehensive compliance standards for automated trading systems and ensures solid risk control while maintaining market integrity. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent Pre-Trade Controls, automated Risk Management systems, and strategic Algorithmic Trading optimization with complete IP protection.
MiFID ESMA Guidelines define uniform supervisory standards and ensure harmonized application of MiFID provisions across EU member states. As a leading AI consultancy, we develop customized RegTech solutions for intelligent ESMA Guidelines implementation, automated Supervisory Convergence, and strategic compliance optimization with complete IP protection.
The MiFID II best execution obligation requires investment firms to take all sufficient steps to obtain the best possible result for clients when executing orders. We help you develop a robust execution policy, analyse and select appropriate execution venues, and establish transparent monitoring and reporting processes – from RTS 27/28 compliance to ongoing quality assurance.
MiFID II conduct of business rules establish the investor protection framework for investment firms across the EU. They define how firms must classify clients, provide investment advice, disclose costs and govern products — from suitability assessments through cost transparency to product governance. ADVISORI supports firms in the practical, auditable implementation of these obligations.
Data Reporting Services Providers (DRSPs) form the backbone of financial market transparency under MiFID II and MiFIR. As APAs, CTPs or ARMs, they ensure that transaction reports under Art. 26 MiFIR are submitted to competent authorities on time and accurately. ADVISORI advises financial institutions on selecting, connecting and maintaining compliance with these services – including the new requirements from the MiFIR Review 2026.
MiFID II Compliance Framework Implementation requires precise integration of ESMA Guidelines with national supervisory requirements and comprehensive Client Protection. As a leading AI consultancy, we develop customized RegTech solutions for intelligent MiFID II compliance, automated investment services monitoring and strategic market advantages in the European investment services environment with complete IP protection.
MiFID German Implementation requires precise transposition of European directives into German supervisory law with specific BaFin requirements and WpHG integration. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent BaFin compliance, automated WpHG monitoring and strategic German MiFID optimization with complete IP protection.
Implementing MiFID II requires a structured gap analysis, clear project governance and the integration of compliance requirements into processes, systems and governance structures. ADVISORI guides your implementation project from initial assessment to an operational compliance framework.
MiFID II establishes binding protection standards for all investor categories. We support financial institutions in implementing client categorisation, inducement rules, PRIIPs key information documents, information duties and complaints handling – practical and regulatory-compliant.
Position limits under Article 57 MiFID II cap the maximum net position in commodity derivatives, aiming to prevent market abuse and ensure orderly price formation. ADVISORI supports financial institutions and trading firms in the compliant implementation of position limit requirements — from initial assessment through ongoing position management to regulatory reporting.
MiFID II and the upcoming MiFIR review present financial institutions with far-reaching compliance challenges. Our readiness assessment systematically identifies gaps across investor protection, transparency and market infrastructure – and develops a prioritised roadmap for your sustainable compliance.
Since 2018, MiFID II requires the separation of research costs from trade execution fees. Investment firms must pay for research through a Research Payment Account (RPA) or from their own resources. ADVISORI supports institutions in fully implementing unbundling requirements — from gap analysis through RPA setup to ongoing compliance monitoring.
MiFID III Updates & Changes require strategic adaptation to significant ESMA developments with Digital Finance integration, Crypto Assets regulation, and ESG compliance harmonization. As a leading AI consultancy, we develop tailored RegTech solutions for intelligent MiFID III transformation, automated regulatory adaptation, and strategic market advantages in the evolved European investment services environment with complete IP protection.
MiFID Market Structure defines the architecture of modern financial markets and ensures optimal market transparency through structured Trading Venue regulation and systematic Best execution requirements. As a leading AI consultancy, we develop customized RegTech solutions for intelligent market structure automation, optimized Trading Venue compliance, and strategic Market Structure excellence with complete IP protection.
Ensure your institution's long-term compliance with complex MiFID requirements through our comprehensive ongoing compliance approach. We implement solid governance structures, automated monitoring mechanisms, and proactive adaptation processes that guarantee continuous compliance and minimize regulatory risks.
The Reasonable Commercial Basis (RCB) is a core requirement under Art.
13 MiFIR. It obliges trading venues and data providers to make market data available at fair, reasonable and non-discriminatory prices. Pricing must be related to the actual costs of producing and disseminating the data. The new ESMA Regulatory Technical Standards (November 2025) strengthened the concrete RCB pricing requirements, including detailed disclosure obligations and a prohibition on unreasonable penalty clauses in market data contracts.
The Consolidated Tape Provider (CTP) consolidates market data from all European trading venues into a single continuous data stream. In March 2026, ESMA selected EuroCTP as the first CTP for equities and ETFs. Operations are expected to launch in July
2026 with a five-year licence term. For financial institutions, this means a potentially cheaper and simpler path to consolidated pre- and post-trade data – a possible counterweight to the high market data costs charged by individual exchanges.
The new Regulatory Technical Standards on RCB pricing entered into force on
23 November 2025. Market data providers authorised before that date benefit from a transition period until
22 August
2026 to align existing contractual arrangements. ESMA also withdrew its previous RCB guidelines in February 2026, as these have been replaced by the new RTS. Financial institutions should review existing contracts promptly and identify any adjustment requirements.
Unbundling refers to the separation of market data packages into individual data types (e.g. pre-trade data, post-trade data, order book data). MiFIR requires trading venues to offer market data not only as a bundle but also individually. This aims to prevent users from paying for data they do not need. Unbundling is closely linked to the RCB obligation: when data is available separately, the individual pricing must also be reasonable and transparent.
We systematically analyse all existing market data contracts against the RCB requirements under Art.
13 MiFIR and the new ESMA RTS. We review pricing models, penalty clauses, bundling arrangements and disclosure obligations. Based on the gap analysis, we develop concrete recommendations: contract adjustments, renegotiations with data providers and the establishment of internal cost allocation structures for end-to-end transparency documentation.
Cost transparency in market data goes beyond regulatory obligation: it is the foundation for informed procurement decisions and budget management. Institutions must be able to trace which costs arise for which data types, usage categories and business units. The new ESMA RTS require data providers to deliver a detailed cost breakdown. On the buy side, clean cost allocation enables internal recharging and demonstration of compliance to auditors and supervisory authorities.
The MiFIR review (often referred to as part of the MiFID III package) introduces significant changes: the legal basis for the Consolidated Tape Provider was established, RCB requirements were specified through binding RTS, and the payment for order flow (PFOF) obligation will be phased out by June 2026. For data providers this means stricter transparency obligations; for consumers the CTP opens the long-term possibility of accessing a central, more cost-effective data stream.
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