Q&A · ESMA
Transactions that should be included in the calculations
Answered
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For the systematic internaliser tests, a firm dealing on own account with a counterparty that is not a regulated financial institution is always executing a client order; when dealing with a financial institution it must decide which side is acting for a client, by transaction, transaction type or counterparty type, using indicators such as client classification and who initiated the trade.
Details
| Reference | ESMA_QA_1582 |
|---|---|
| Issuer | ESMA |
| Published | 10 Oct 2025 |
| Answered | 10 Oct 2025 |
| Submitted | 3 Oct 2017 |
| ESMA topics | Systematic internaliser regime |
| Earlier Q&A document | ESMA 70-872942901-35 MiFIR transparency Q&A, Q&A 7.7 |
Provisions it relates to
- Article 4 MiFID II · DefinitionsESMA rulebook
- MiFID II (whole act)Explicit reference