MiFID/MiFIR
[DISCLAIMER] The information below provides general background on MiFID and MiFIR. It does NOT contain personal recommendations or constitute (investment) advice.
1. Introduction to MiFID and MiFIR
The Markets in Financial Instruments Directive (“MiFID”) and the Markets in Financial Instruments Regulation (“MiFIR”) form the core regulatory framework governing the provision of investment services, trading of financial instruments and transparency in EU financial markets. MiFID II (Directive 2014/65/EU) enhances conduct‑of‑business rules, investor‑protection standards and transparency requirements for investment firms. It also imposed organisational obligations relating to governance, controls and record‑keeping. MiFID II entered into force on 3 January 2018.
MiFIR (Regulation (EU) 600/2014) provides directly applicable EU rules on pre‑ and post‑trade transparency, transaction reporting and mandatory trading on regulated trading venues, supporting market integrity and uniformity. MiFIR became applicable simultaneously with MiFID II in January 2018.
Together, these rules aim to ensure:
MiFID and MiFIR apply to almost all financial instruments, including equities, bonds, derivatives, structured products and emission allowances.
2. MiFID III & MiFIR II – The latest reforms
The revisions to the MiFID and MiFIR frameworks by the EU - commonly grouped under the label MiFID III and MiFIR II - became legally effective as of 28 March 2024 and are being implemented in phases. Amendments to MiFID had to be transposed into national law, whereas changes under MiFIR applied directly as they entered into force, without requiring national implementation measures.
The updated regulatory framework introduces several important refinements that are relevant for clients and counterparties engaging in EU financial markets:
Designated Publishing Entity (“DPE”)
The reforms introduce the possibility for investment firms to act as a Designated Publishing Entity (DPE). Rabobank has obtained DPE status under MiFIR since 20 January 2025 and can act in the capacity of a DPE for the following classes of financial instruments: bonds, interest rate derivatives, structured finance products, ETCs, ETNs and Emission Allowances. This implies that Rabobank, where acting as a Designated Publishing Entity, will be responsible for making applicable over-the-counter (OTC) transactions public through an Approved Publication Arrangement (APA), in accordance with the post-trade transparency requirements under MiFIR. Where Rabobank is designated as the publishing entity for a transaction, the bank will publish the relevant trade reports through the selected APA, subject to the applicable transparency rules, deferrals and publication requirements. Such publications form part of Rabobank's obligations under the post-trade transparency framework under MiFIR.
A similar regime has been introduced in the United Kingdom where Rabobank has obtained status as Designated Reporter (DR).
Consolidated tape
In addition, the creation of a more robust EU‑wide consolidated tape offers a unified and standardized overview of pricing and trading volumes across multiple trading venues. By centralizing this information, the regime aims to increase overall market transparency while lowering the cost associated with accessing market data.
Transparency requirements
Finally, transparency requirements have also been strengthened more broadly. The revised rules apply to equity instruments, bond markets, derivatives and emission‑related products, thereby improving both pre‑trade and post‑trade visibility and supporting a more coherent and efficient market structure.
3. How these rules affect transactions with Rabobank
For clients and counterparties, MiFID and MiFIR mean:
Rabobank provides accurate and timely information about products, risks, costs, and execution policies.
We follow strict rules to achieve the best possible outcome when executing client orders, supported by enhanced monitoring and reporting obligations.
As transparency requirements evolve, Rabobank will adapt its reporting and publication processes in line with MiFIR developments (including DPE obligations where applicable).
Our internal governance, product oversight, and conduct standards are aligned with MiFID and MiFIR enhancements to ensure appropriate protection for all clients.
4. Rabobank’s Commitment
Rabobank continuously monitors developments in EU financial markets regulation, including forthcoming ESMA technical standards and updates to system and reporting requirements.
We are committed to: