If you've worked in the industry long enough, you've probably learned to be a little skeptical of regulatory implementation dates.
Many initiatives have evolved, been delayed or changed course along the way, so it's understandable that some organizations have taken a wait-and-see approach to the latest regulations about Reasonable Commercial Basis (RCB).
After all, we've been talking about elements of this legislation for years.
Recent industry coverage, including an article in WatersTechnology, has highlighted concerns that many firms remain underprepared for what's ahead.
With the ESMA (European Securities and Markets Authority) transition period ending on 22 August 2026, organizations have a narrowing window to prepare. Meanwhile, exchanges are rolling out their new pricing and licensing models on different timelines, with Deutsche Börse among the first to implement its changes on 1 August 2026.
Many market data teams have already launched internal programs to assess the impact of the changes. Over the past few months, we've been working closely with clients and engaging with exchanges as those programs have gathered pace. While every organization’s starting point is different, we're seeing the same operational challenges emerge time and again.
The question is less about, "What does the regulation say?" and more about "What do we need to do differently, and how do we integrate the new requirements into daily routines?"
In this article, we explore the five operational priorities that, from our conversations across the industry, market data teams should be thinking about right now.
The Reasonable Commercial Basis (RCB) framework forms part of the EU's MiFID II/MiFIR Review and is designed to make market data pricing fairer, more transparent and easier to understand. For market data users, the changes are expected to introduce:
Greater transparency around exchange pricing.
Revised client categorization and licensing models.
More structured declaration and reporting requirements.
A move away from routine audits without cause.
Different implementation approaches across European exchanges.
Although the objectives are consistent across the market, exchanges are implementing the framework in different ways. That means firms operating across multiple venues will need to understand and manage a range of different pricing, licensing, and declaration models.
It's easy to see why most of the headlines have centered around cost.
Will firms pay more? Will they pay less?
The honest answer is: it depends.
Smaller organizations with relatively straightforward usage models may well benefit from the new pricing structures. Larger institutions, particularly those with significant non-display usage, more complex licensing arrangements and extensive exchange relationships, may experience a very different outcome.
In fact, one of the consistent messages coming out of our client conversations is that pricing is only part of the story.
The operational effort required to understand, validate and implement these changes may ultimately prove more significant than any immediate movement in exchange fees.
At the same time, firms also need to consider the wider market backdrop. The introduction of the Consolidated Tape is creating additional commercial pressures across the exchange landscape. While RCB is designed to improve transparency and fairness, exchanges are also adapting their commercial models to reflect wider regulatory changes. The result is that organizations shouldn't assume overall market data costs will automatically fall.
The priority isn't trying to predict whether costs will rise or fall. It's understanding how the changes will affect your own operating model.
Perhaps the biggest operational challenge isn't building new processes. It's revisiting the ones you've already spent years perfecting.
Many organizations have invested heavily in automating declaration processes, entitlement reporting and license administration. Those processes often reflect years of refinement and significant internal investment by specialist subject matter experts.
The challenge now is that different exchanges are introducing different operating models.
One exchange may require a revised declaration process. Another may introduce different client categories. Another may split reporting requirements between products that fall within RCB and those that remain outside its scope.
We're already aware of examples where firms previously submitted a single declaration now need multiple declarations, depending on the exchange, product and use case.
That may sound like a relatively small administrative change. In reality, it can mean revisiting automated workflows, rebuilding reporting logic and validating processes that have remained largely untouched for years.
The organizations making the best progress are the ones taking the time to understand where their existing operating model still works, where it doesn't, and where outsourcing the research of required solutions to 3rd parties stands reassessing.
One theme has come through in almost every conversation we've had. There is no single prescribed European implementation model.
Different exchanges are taking different approaches to client categorization, declaration requirements and reporting timetables.
Take Deutsche Börse as one example. Organizations may now find themselves managing different declaration approaches depending on whether products fall within the RCB framework or remain outside it. Processes that historically covered an entire exchange relationship may now need to distinguish between different product groups.
Elsewhere, exchanges are introducing different client categories, revised license structures and alternative reporting models.
None of these changes are unmanageable in isolation. Collectively, however, they create a level of operational divergence that many firms simply haven't had to deal with before.
For organizations operating across multiple exchanges, a single, standardized operating model is becoming much harder to maintain. That means inventories, entitlement models and governance processes all deserve a fresh review.
One of the more welcome aspects of the new framework is the move away from routine audits without cause. For many market data managers, that's a positive development.
Unexpected audits have traditionally demanded significant time, resources and disruption across multiple teams.
The trade-off, however, is that exchanges are placing much greater emphasis on declarations.
Rather than relying on periodic audits to validate usage, organizations will increasingly need to demonstrate ongoing compliance through more detailed reporting and regular declarations.
Based on the conversations we're having across the industry, firms should expect declaration processes to become more detailed and, in many cases, more complex. Questions around application usage, license types, entitlement models and business activities are likely to require greater scrutiny than before.
That places greater emphasis on the quality of internal inventories and the accuracy of entitlement data. In many cases, organizations with robust governance may actually find themselves in a stronger position than they were previously.
Those relying on fragmented records, manual spreadsheets or historic assumptions may find the new declaration process exposes gaps that have never previously been tested.
It would be easy to view RCB as another regulatory project. We think that's missing the bigger opportunity.
Every significant regulatory change shines a light on operational models. The organizations that come through this transition most successfully won't necessarily be those paying the least for market data.
They'll be the ones that finish the process with:
a clearer understanding of their market data inventory
stronger entitlement governance;
more resilient declaration processes;
better visibility of licensing obligations; and
greater confidence in the accuracy of the information they're providing to exchanges.
Those capabilities won't just help organizations respond to RCB. They'll strengthen market data operations long after these particular regulatory changes have settled.
The RCB changes won’t be the last regulatory or commercial shift facing market data teams, but they do provide a valuable opportunity to take stock of existing processes, challenge long-held assumptions and build a stronger foundation for the future.
Whether you're already well into your preparations or just beginning to assess the impact, having the right expertise and visibility can make all the difference.
At TRG Screen, we're already working alongside clients and exchanges to help navigate these changes. We’ll continue to share what we're learning and our recommendations as the industry moves through the transition. We’d love to hear your thoughts on the changes. Are your teams ready to respond? What impacts are you expecting? We welcome your comments below, or if you want to chat 1-1 about the changes and how to best prepare for them, please reach out to your TRG Screen representative or message us at info@trgscreen.com.
European Securities and Markets Authority (ESMA) – The EU's financial markets regulator has published an overview of the RCB framework, implementation timetable and supporting technical standards.
Commission Delegated Regulation (EU) 2025/1156 – The legal text establishing the RTS on Reasonable Commercial Basis.
You should also review implementation guidance from the exchanges relevant to your organization, as implementation dates, client categories and reporting requirements vary by venue.