MiFID II introduced a requirement for all investment firms to publish trades in financial instruments executed OTC, i.e. outside the rules of a trading venue. This requirement was initially introduced for shares in 2007 but was extended to cover all asset classes with the introduction of MiFID II in January 2018 such as:

  • All types of bonds incl. structured bonds
  • Fixed income derivatives
  • Equity derivatives
  • Emission allowances
  • FX derivatives 

For each trade executed OTC, the investment firm is required to publish the price, volume and time of agreement along with various other data elements for the individual trade. This information has to be made public as close to real-time as possible. 

The local competent authority can authorize deferral of publication. For shares, depository receipts, ETFs, and other similar instruments the deferral allowed may be between 60 minutes and end of next trading day, where the deferral allowed for bonds, structured finance products, emission allowances, and derivatives may typically be two days but can in certain cases be up to four weeks. 

Investment firms trading OTC are required to publish these trades via an Approved Publication Arrangement (APA). Being an APA requires certification by the local competent authority. Nasdaq has APA certification in Sweden.


An investment firm trading OTC must be able to assess whether their counterparty is an SI or not. The counterparty’s SI status affects the investment firms reporting obligations.  

Following ESMA’s announcement that they will not make SI data publicly available, industry participants needed to solve a common problem of SI Data collection and dissemination to facilitate accurate post trade reporting. With that the SI Registry Data Group was formed. 

Nasdaq APA has joined this collaboration and will offer its clients an add-on service that facilitates readiness for the SI regime coming into force on September 1, 2018. The service will be free of charge for members of the Nasdaq APA. 

Nasdaq together with currently 6 of the major other APAs in EU are collecting SI reference data from SIs on a voluntary basis and in return the SIs will receive a masterfile containing SI data from all the other APAs and their contributing SIs.

Read more:


  • When MiFID II introduces a requirement for all investment firms to publish trades in financial intruments on OTC, outside of the trading venue. 
  • For each trade executed OTC, the investment firm is required to publish price, volume, and time of agreement. 
  • Being an APA requires certification by the local competent authority.


Nasdaq’s APA service covers all relevant instruments subject to the OTC publication requirement, i.e. not only all asset classes but also all covered EU securities. Customers will therefore be able to use the Nasdaq APA for all their OTC trades to be published. 

The service will support the use of deferred publication of trades where applicable. This will allow for the APA to administer deferrals on behalf of the customers instead of requiring all customers to administrate deferrals internally. Customers can send trades in real-time to the APA stating that the trade should be deferred and the time of publication to be applied. The APA will then publish the trade at the end of the applicable deferral period.

The APA will ensure proper automatic quality checks when receiving trade reports to minimize erroneous trades being sent to the market. If the APA receives a trade for publication that seems likely to be erroneous, the trade report will be rejected and sent back to the submitting customer for verification.

Customers can also make use of Genium INET for publication of OTC trades to be CCP cleared for instruments listed on our Nordic markets. 

This means clients can submit trades for publication via the following protocols:

  • Fix 5.0 (all instruments)
  • OMnet (derivatives to be CCP cleared at Nasdaq Clearing)

Customers can also send OTC trade reports manually by using the relevant Nasdaq GUI available, i.e. Trading Workstation (Genium INET) and Nordic Workstation (INET).

OTC trade reports sent to the Nasdaq APA will be published via Nasdaq’s data feed which provides extensive global coverage. All trades will also be published on Nasdaq’s website.

The APA will be open for publication of OTC trades between 08:00 CET and 22:00 CET.



The APA services will be based on the INET system infrastructure— the same set-up used for manual trades in Nordic listed equities. Most existing exchange customers will enjoy significant benefits from knowledge of technology and connectivity already in place.