What are APAs, ARMs and CTPs, and who supervises them today?

An approved publication arrangement (APA) publishes trade reports on behalf of investment firms, meeting their post-trade transparency duties. For each trade it makes public at least the instrument identifier, the price, the volume, the time of the trade and the time it was reported, the price notation, the code of the venue (or SI or OTC where the trade was off-venue) and any special conditions, as close to real time as technically possible.

An approved reporting mechanism (ARM) sends transaction reports to the authorities on behalf of investment firms, as quickly as possible and no later than the close of the working day after the transaction. It must check that reports are complete, catch gaps and obvious mistakes made by the firm, tell the firm and ask it to resubmit; mistakes the ARM itself causes, it corrects and resends. A consolidated tape provider (CTP) collects market data from trading venues (regulated markets, MTFs and OTFs) and APAs and combines it into a single continuous electronic live data stream; since the 2024 MiFIR review the tape for shares and ETFs carries the best bid and offer as well as completed trades.

All three need a management body with the collective knowledge, skills and experience to understand the business, arrangements to prevent conflicts of interest, and sound security to protect the data and prevent unauthorised access.

The exam material describes DRSPs being authorised by CySEC and kept on its public register. That changed on 1 January 2022, when Regulation (EU) 2019/2175 moved authorisation and supervision of APAs, ARMs and CTPs to ESMA. National authorities kept only APAs and ARMs that qualify for a derogation because of their limited size and reach, and in Cyprus the provisions of Law 87 on DRSPs were deleted in 2021.

The MiFIR review of 2024, Regulation (EU) 2024/791, went further for CTPs: ESMA selects one consolidated tape provider per asset class through a tender. In July 2026 ESMA authorised the first CTP, for shares and exchange-traded funds, with a transition period until 30 September 2026 to prepare the start of its service.

APAs and CTPs, like trading venues and systematic internalisers, must make market data available on a reasonable commercial basis. Fees reflect what it costs to produce and distribute the data, plus a reasonable margin, and access must be non-discriminatory. Fees may differ only between client categories set on factual, easily verifiable criteria, with the same margin for every client in a category and each client in one category only. Each provision of data is charged only once, and data is not bundled with other services. The exam material describes the earlier version of these rules, with fees per end user, prices set by level of disaggregation and differences proportionate to the value of the data.

Each provider publishes a market data policy with its fee schedules, client categories, terms and cost methodology, and must give clients at least 90 days' notice of any unilateral change to fees or terms; a client facing less favourable terms may withdraw. These rules sit in MiFIR Article 13 and Delegated Regulation (EU) 2025/1156, which has applied to existing providers since 23 August 2026. Trading venues, APAs and systematic internalisers must also make data free of charge 15 minutes after publication. The exam material applies that 15-minute rule to CTPs too; since 28 March 2024 CTPs instead give free access to retail investors, academics, civil society organisations and supervisors.