What must trading venues publish before and after trades in shares and ETFs?

MiFIR has two transparency regimes, one for equity and one for non-equity instruments, so the first step is always to sort the instrument. Equity instruments are shares, exchange-traded funds (ETFs), depositary receipts, certificates and other similar financial instruments. Non-equity instruments are bonds, derivatives, structured finance products and emission allowances, covered in What transparency applies to bonds, derivatives and other non-equity instruments? The duties in this note fall on market operators and investment firms that operate a trading venue. For shares and other equity instruments, that means a regulated market or an MTF, because an OTF cannot trade them. How venues admit instruments and members, and control algorithmic trading and direct electronic access, is covered in How do regulated markets admit instruments and members, and control algorithmic trading?

Several equity rules depend on whether a share has a liquid market. Since 2 March 2026 a share traded daily has a liquid market if it passes all three tests: a market capitalisation of at least €100 million, an average of at least 250 trades a day, and an average daily turnover of at least €1 million. The capitalisation test replaced the former free-float test. If fewer than five shares first admitted in a Member State pass, the competent authority may treat others as liquid, up to five in total. Liquidity matters for the negotiated-trade waiver and for systematic internalisers, which publish quotes only in liquid shares (see What must a systematic internaliser quote, and how must it execute client orders?).

Under Article 3(1), a venue makes public the current bid and offer prices for the shares and other equity instruments traded on it, and the depth of trading interest at each price. Actionable indications of interest count too. The information must be available to the public continuously during normal trading hours.

The requirement is calibrated to the type of trading system. MiFIR names four for equity: order-book systems, periodic auctions, quote-driven systems and hybrid systems. Voice trading is not on the equity list. The exam material's non-equity rules add voice trading systems to the list. Since 28 March 2024 that difference no longer holds, because non-equity pre-trade transparency now applies only to central limit order book and periodic auction systems. The venue must also give systematic internalisers, which publish their own quotes, access to the arrangements it uses to publish this information, on reasonable commercial terms and without discrimination. A venue may be allowed not to publish under the waivers explained in When can a venue trade shares without pre-trade transparency?

After execution, the venue publishes the price, volume and time of each transaction in equity instruments, as close to real time as technically possible (Article 6). Investment firms that must publish their own OTC trades under Article 20 can use the venue's publication arrangements; access must be on reasonable commercial terms and must not discriminate. Pre-trade and post-trade data must be offered separately. Market data must be sold on a reasonable commercial basis and made free of charge 15 minutes after publication; the details, and the rules for APAs and consolidated tapes, are in What are APAs, ARMs and CTPs, and who supervises them today?

Publication may be delayed only with CySEC's authorisation. Under Article 7, CySEC may allow a venue to defer publication based on the type or size of the transaction, in particular trades that are large in scale compared with normal market size. The venue needs CySEC's prior approval of its proposed arrangements and must clearly disclose them to market participants and the public. ESMA monitors how deferrals are used and reports to the European Commission every year. If another Member State's authority disagrees with a deferral that CySEC has authorised, it may refer the matter to ESMA. The 2024 review did not change these equity deferral rules. For bonds, structured finance products and emission allowances, by contrast, deferrals have not needed CySEC's authorisation since 2 March 2026.