European securities regulator ESMA has published its Opinion on the Trading Venue Perimeter, setting out when systems and facilities are considered multilateral and need authorisation as a trading venue under MiFID II/MiFIR.
The document, published on ESMA’s library on 1 May 2026, follows the authority’s 2023 final report and sets out supervisory guidance.
The opinion focuses on the venue-perimeter treatment of technology providers, request-for-quote (RFQ) systems, and platforms that pre-arrange transactions.
On RFQ systems, ESMA’s position is that these should be considered multilateral, including arrangements where a client requests a quote from only one dealer, if a third party operates the system and sets the rules governing how trading interests interact.
For technology providers, ESMA says a platform falls outside the venue perimeter only when it aggregates and broadcasts interests without enabling communication, negotiation, or execution between parties.
On pre-arranged transactions, ESMA says firms can operate outside the perimeter only when every arranged trade is formalised on a trading venue and benefits from a pre-trade transparency waiver.
ESMA said it expects national competent authorities to “require firms to take appropriate action to swiftly apply for authorisation as a trading venue where necessary.”
