Global Trustee and Fiduciary Services Bite-Sized Issue 2 2025

7 QUICK LINKS BENCHMARKS REGULATION CRYPTOASSETS DORA EMIR FSB MIFID II/MIFIR MMF SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE INTERNATIONAL LUXEMBOURG NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2025 MIFID II/MIFIR ESMA Announces Start of DPE Regime and End of Publication of SI Data On 24 January 2025, the European Securities and Markets Authority (ESMA) reminded market participants that the new regime for the reporting of Over the Counter (OTC) transactions for post-trade transparency purposes becomes fully operational on 3 February 2025. ESMA also informed stakeholders that the quarterly publication of systematic internalisers (SI) data will be discontinued with immediate effect. Following the MiFIR review, ESMA says that the responsibility for reporting OTC-transactions will shift from SIs to the new Designated Publishing Entities (DPEs)and that the DPE regime allows National Competent Authorities (NCAs) to grant the status of DPE to investment firms. DPEs, when they are party to a transaction, will need to make these transactions public through an approved publication arrangement (APA). Also, following the application of the MiFID II amendments, ESMA says it will no longer be necessary for it to perform SI calculations from September 2025. In view of the resources needed to perform the calculations and the fact that the regime will end shortly, ESMA has decided to discontinue the voluntary publication of quarterly SI calculations data already now. This action will also reduce the administrative burden for investment firms. Consequently, ESMA says that the mandatory SI regime will no longer apply from 1 February 2025, and investment firms will not need to perform the SI-test. However, investment firms can continue to opt into the SI-regime. Link to ESMA Announcement here ESMA Launches Selection of the Consolidated Tape Provider for Bonds On 3 January 2025, the European Securities and Markets Authority (ESMA) launched the first selection procedure for the Consolidated Tape Provider (CTP) for bonds. ESMA says that entities interested in applying are encouraged to register and submit their requests to participate in the selection procedure by 7 February 2025. ESMA says that the CTP aims to enhance market transparency and efficiency by consolidating trade data from various trading venues into a single and continuous electronic stream. This consolidated view of market activity should help market participants to access accurate and timely information and make better-informed decisions, leading to more efficient price discovery and trading. ESMA will assess the received requests against the exclusion and selection criteria and will invite the successful candidates to submit their application. ESMA intends to adopt a reasoned decision on the selected applicant by early July 2025, and says that the successful applicant will be selected to operate the CTP for a period of five years and invited to apply for authorisation with ESMA without undue delay. Further information about the process is available on ESMA’s dedicated webpage. Link to ESMA Press Release here