The provision of separate post‐trade data products by FESE members as well as the overall availability of 15‐minutes delayed data free of charge will support data consolidation with regard to cost efficiency. However, given the small share occupied by exchanges in the overall cost of data (8% to 15%, with a downward trend), bringing overall costs down will require a collaborative effort on the part of everyone.

Similarly, FESE’s work on trade identifiers will further improve the consolidatibility of equity data. However, no matter what actions are taken to improve the consolidatibility of their data, OTC data needs to improve in terms of not only availability and timeliness but also, most importantly, in terms of quality. A “bundling” by consolidation of good and poor quality market data would result in a data consolidation product that would have no practical value or use to anyone. In order to provide a meaningful consolidated view, it is of essence that clear and detailed reporting requirements for OTC data are introduced and supported on a pan‐EU level. This will reduce uncertainty amongst investment firms regarding their reporting duties, thus avoiding over‐ or under‐reporting and improve the reliability of OTC post‐trade data. Overall, the introduction of the Approved Publication Arrangements (APAs) regime will play an important role in the achievement of this objective.

With regard to timeliness, reduced reporting times for OTC trades would help to align the information value between organised trading venues and OTC. Otherwise, non‐reduced reporting time OTC data would be consolidated with real‐time data made available by organised trading venues (in milliseconds after the trade takes place) and would again result in a “bundling” of varying data qualities.

FESE progress report on Equity Market Data_FINAL.pdf">Full press release