BNP Paribas Global Markets has been a registered Systematic Internaliser (SI) since the inception of MiFID II/MiFIR in January 20181. As regulatory landscapes evolve in the EU and UK, the bank is adjusting its SI status in response to the recent simplification brought by the MiFIR Review and the UK Wholesale Market Review (WMR).
What is a Systematic Internaliser (SI)?
As per the EU MiFID II/MiFIR, an SI is an investment firm which, on an organised, frequent and systematic basis, deals on own account in equity instruments by executing client orders outside a regulated market, an MTF or an OTF, without operating a multilateral system, or which opts in to the status of SI.
Transparency obligations: MiFID II/MiFIR require SIs to publish firm bid and offer quotes for liquid equity and equity-like instruments, at specified minimum quote sizes. In the UK, the FCA is expected to formalise rules covering these activities by the end of 2025, mirroring the EU framework while applying any UK‑specific adjustments.
Remaining systematic internaliser for equity and equity-like instruments
BNP Paribas Global Markets will maintain its SI status for Equity shares, Depositary Receipts, Exchange-Traded Funds (ETFs), and other Equity-like Financial Instruments. This decision aligns with the regulatory changes that continue to recognise the role of SIs in equity markets.
Maintaining our SI status for equities and ETFs ensures continuity in our commitment to providing liquidity and efficient trade execution for our clients in these asset classes.
Sean Barwick, Director, Regulatory and Public Affairs, BNP Paribas Global Markets
De-registering as systematic internaliser for bonds and derivatives
In response to the EU MiFIR Review and the anticipated UK WMR changes, BNP Paribas Global Markets will de-register as an SI for all bonds, structured finance products, securitised derivatives, and other derivatives. This move follows the removal of mandatory SI obligations for these asset classes.
The regulatory shift away from SIs for bonds and derivatives allows us to streamline our reporting processes and focus on our core liquidity provision strengths.
Quentin van Lidth, Director, Regulatory and Public Affairs, BNP Paribas Global Markets
Regulatory context and simplification
The EU MiFIR Review, effective from March 2024, introduced some essential simplification in terms of concepts and requirements. It removed the mandatory SI regime and all related obligations for bonds and derivatives. Key changes include:
- No more pre-trade transparency requirements
- No more instrument referential data (ISIN) reporting
- Clearer framework and responsibility for Post-Trade Transparency reports (with a Designated Publishing Entity (DPE) regime)
Similarly, the UK has followed suit regarding the SI obligations (introducing a Designated Reporter (DR) regime) and is anticipated to eliminate the SI concept for those asset classes.
BNP Paribas Global Markets has registered as a DR in the UK and a DPE in the EU, continuing to facilitate post-trade transparency (PTT) reporting for its clients.
Impact on reporting
The de-registration of SI status for bonds and derivatives will impact reporting requirements. Notably:
- BNP Paribas Global Markets will cease creating and reporting ISINs for OTC derivatives to ESMA FIRDS
- Adjustments will be made to reporting fields, namely “venue of execution” for MiFIR Transaction Reporting and EMIR reporting
BNP Paribas remains committed to transparency and compliance with regulatory requirements. Clients are encouraged to review these changes with their legal and compliance teams to assess potential impacts on their reporting frameworks.
For further information please take a look at BNP Paribas’ Factsheet on BNP Paribas Global Markets SI Status or our previous article on MiFIR transparency: who holds the responsibility to report?.
You may also consult the joint paper by AFME, ICMA and ISDA, Joint Paper on Removal of SI Regime for Derivatives and Bonds in the EU and UK, 13 October 2025. If you have any comments or questions, please contact the BNP Paribas EMEA Regulatory team or your usual BNP Paribas representative.
Disclaimer: This article is for informational purposes only and should not be relied upon for legal, tax, accounting, regulatory, or financial advice.
- See press release “BNP Paribas to Opt in to Systematic Internaliser Regime Under MiFID II” published in 2017 and our dedicated factsheet. ↩︎