July 2016

The Financial Market Infrastructure Act (FMIA) and its implementing Ordinances (FMIO and FMIO-FINMA) entered into force on January 1st, 2016. In order to implement the new requirements, the FMIA and the FMIO provide for various transitional periods. The financial market infrastructures were in particular provided with a one-year transitional period to fulfil the duties as provided under Art. 129 para. 1 and 2 of the FMIO. These duties mainly concern the pre- and post-trade transparency, the high-frequency trading, as well as the record-keeping duty and the reporting duty to the trading venues, but not to a Trade Repository as set out under Art. 104 FMIA.