Comments
17th of December 2021

Comment on Amendments to MiFID II Requirements

German Banking Industry Committee Capital markets

GBIC critically comments on ESMA's proposed amendments to the revision of MiFID II requirements on Best Execution Reports (RTS 27 / RTS 28). GBIC continues to be in favor of a general abolition of both reporting requirements. The data to be published by execution venues (RTS 27) and investment service providers (RTS 28) do not offer any informative added value for clients and are accessed in negligible numbers.

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Stellungnahme MiFID II-Anforderungen

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27th of March 2025

GBIC interpretation of the DORA constellation

‘ICT service as part of a regulated financial service’

The background to the paper is the Q&A of the European Supervisory Authorities (EBA, ESMA, EIOPA) of 22 January 2025, which provides the EU Commission's clarification on this constellation.