On 17 November 2015, ESMA published a note on delaying the implementation of the Markets in Financial Instruments Directive ("MiFID") II. It is unlikely that the Level 2 provisions will be published until March 2016, leaving insufficient time to develop the systems for MiFID II implementation.
ESMA identifies four areas where the complexity, interaction and need for a harmonised start date of the systems are especially acute: reference data, transaction reporting, transparency parameters and position reporting.
ESMA also discusses the pros and cons of different options for imposing an implementation delay.
The full text of the note is available here:
https://www.esma.europa.eu/search/site/MiFID%2520II%2520Implementation%2520Day?page=1
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