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ESMA’s statement (PDF) takes a pragmatic approach to how MiFID II will operate in the EU27, given that a number of the calculations will look back to a period when UK data was included.
By the end of February 2019, we expect to set out our approach to using our temporary powers to operate MiFID II in the UK. Full details will be provided then, but the powers were provided to us to help avoid significant short-term disruption in a no-deal scenario.
Our approach will provide continuity in the operation of the transparency regime in the UK, taking into account trading activity in both the UK and the EU27, where appropriate and practicable.