With just 364 days left to go, the MiFID II go-live date looms large. But with complex regulation spanning several hundred pages of text it is no great surprise that some MiFID II deadlines will come in earlier than 3rd January 2018, while others leave more breathing space. For example, trading venues must submit their waiver applications to their relevant competent authorities by 1st February 2017 for equities and no later than 1st June 2017 for bonds and derivatives. Further off, the deadline for investment firms to register as a Systematic Internaliser is 1st September 2018. Non-discriminatory access to and obligation to licence benchmarks doesn't apply until 3rd January 2020 and the non-equity consolidated tape may not be introduced until beyond September 2019.
The reality is that with all of these different dates so horribly intertwined, each company needs its own customised go-live roadmap, making sure it focuses on the right things first.