THE APA
TRADE ASSOCIATION

ABOUT

The APAA represents common APA interests on regulations and laws impacting APA businesses in the EU and UK and the associated supervisory framework to ensure efficient dialogue with regulatory policymakers.

The APAA will focus on developing and supporting the adoption of best practice with the common aim of improving industry data quality.

The APAA will aim to assist authorities and regulators with advice on practicalities related to implementing laws and rules bearing in mind the practicalities of the data sets involved.

The six members are affiliates of
Bloomberg, Cboe Europe, London Stock Exchange, MarketAxess, Nasdaq Nordic and Tradeweb Markets.

MISSION STATEMENT

August 2025

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September 2022

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MEMBERS

  • EU DRSPs
  • Bloomberg Data Reporting Services B.V.
  • UK DRSPs
  • Bloomberg Data Reporting Services Limited
  • EU DRSPs
  • Bloomberg Data Reporting Services B.V.
  • UK DRSPs
  • Bloomberg Data Reporting Services Limited
  • EU DRSPs
  • UnaVista TRADEcho B.V.
  • UK DRSPs
  • London Stock Exchange plc
  • EU DRSPs
  • MarketAxess Post-Trade B.V.
  • UK DRSPs
  • MarketAxess Post-Trade Limited
  • EU DRSPs
  • Nasdaq Nordic
  • EU DRSPs
  • Tradeweb EU B.V.
  • UK DRSPs
  • Tradeweb Europe Limited

ENQUIRY

Membership of the APAA is open to all market participants that meet the established membership eligibility criteria.

The activities of the association are governed by members of APAA’s Executive Committee, who are elected by the general membership and are responsible for the executive management of the association.

Request more information about the APAA, including membership enquiries.

PUBLICATIONS

APAA RESPONSE TO FCA CP25/31

submission

February 2026

APAA RESPONSE TO FCA CP25/20

submission

September 2025

APARMA RESPONSE TO ESMA CP 4

submission

July 2025

APARMA RESPONSE TO ESMA CP 3

submission

October 2024

“ICT SERVICES” DEFINITION IN DORA

Request for clarification

November 2024

APARMA RESPONSE TO ESMA CONSULTATION PACKAGE CP1

Submission

August 2024

APARMA RESPONSE TO ESMA CONSULTATION PACKAGE CP2

Submission

August 2024

APARMA FEEDBACK ON ESMA RTS 1 & 2 PROPOSALS – DATA QUALITY

Position Paper

August 2022

APARMA FEEDBACK ON ESMA RTS 1 & 2 PROPOSALS – IMPLEMENTATION TIMELINE

Position Paper

August 2022

NEWS

UPDATE

AMSTERDAM and LONDON (1 August 2025)

With effect from 1 August 2025 the Executive Committee of the APAA have decided to narrow the focus of the association to purely handled issues related the businesses of Approved Publication Arrangements (APAs) service providers. The association will no longer represent the issues and interests of Approved Reporting Mechanisms (ARMs).

For more information, including membership enquiries, please email contact@apa-association.org

or visit www.apa-association.org.

About the APAA

The APAA represents common APA interests on regulations and laws impacting APA businesses in the EU and UK and the associated supervisory framework to ensure efficient dialogue with regulatory policymakers. The APAA will focus on developing and supporting the adoption of best practice with the common aim of improving industry data quality. The APAA will aim to assist authorities and regulators with advice on practicalities related to implementing laws and rules bearing in mind the practicalities of the data sets involved. Its six founding members are affiliates of Bloomberg, Cboe Europe, London Stock Exchange, MarketAxess, Nasdaq Nordic and Tradeweb Markets. For a full list of licensed member entities please consult the APAA website

LAUNCH

AMSTERDAM and LONDON (27 May 2022)

Six of the industry’s leading Approved Publication Arrangements (APAs) and Approved Reporting Mechanisms (ARMs) today announced the launch of the APAs and ARMs Association (APARMA). Affiliates of Bloomberg, Cboe Europe, Euronext, London Stock Exchange, MarketAxess and Tradeweb Markets have founded APARMA to represent the interests of companies who operate APAs and ARMs in the EU and UK. Established under MiFID II, APAs make public post-trade transparency reports in financial instruments that have been traded off-venue, while ARMs report details of transactions to regulators on behalf of investment firms.

APARMA has been set up to represent the views of its members in relation to regulations and laws impacting APA and ARM businesses and the associated supervisory framework and to promote dialogue with policymakers and regulators. With the rules governing trade and transaction reporting under frequent review and scrutiny, the association will also focus on developing and supporting the adoption of best practice with the common aim of improving industry data quality, transparency and the auditability of transactions in both the EU and UK. As laws for the two financial markets continue to develop post-Brexit, it is increasingly important to bridge the dialogue between regulators and policymakers to facilitate common solutions for global market participants accessing both markets.

Chris Smith, Head of Post Trade Services at MarketAxess and first Chairperson of APARMA, said, “As EU and UK policymakers move to enhance data quality and transparency across financial markets, it’s important that the voices of APA and ARM operators – whose activities are critical to the achievement of policy goals – are heard. APARMA will ensure just that. We’re excited about having a new forum within which we can build a better industry dialogue, share best practice and collectively improve the quality of our data and data services.”

“I look forward to representing the views and interests of existing and new APARMA members, each of which operate and run an important part of financial market infrastructure and who, to-date, have been underrepresented in important industry and regulatory circles,” said David Bullen, Secretary General, APARMA.

Membership of APARMA is open to all market participants that meet the established membership eligibility criteria. The activities of the association are governed by members of APARMA’s Executive Committee, who are elected by the general membership and are responsible for the executive management of the association.

About APARMA

APARMA represents common APA and ARM interests on regulations and laws impacting APA and ARM businesses in the EU and UK and the associated supervisory framework to ensure efficient dialogue with regulatory policymakers. APARMA will focus on developing and supporting the adoption of best practice with the common aim of improving industry data quality. APARMA will aim to assist authorities and regulators with advice on practicalities related to implementing laws and rules bearing in mind the practicalities of the data sets involved. Its six founding members are affiliates of Bloomberg, Cboe Europe, Euronext, London Stock Exchange, MarketAxess and Tradeweb Markets. For a full list of licensed member entities please consult the APARMA website

APAs AND ARMs LAUNCH NEW TRADE ASSOCIATION (APARMA)
Press release

May 2022

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FAQ

FREQUENTLY ASKED QUESTIONS

FAQ

August 2026

The APAA is a trade association of APAs in the EU and the UK, formed in 2022; and the name was changed from APARMA in 2026. The APAA supports the interests of its members and the market at large, helping to develop and support the regulatory agenda and the adoption of best practice with the aim of improving data quality, transparency and the auditability of transactions in financial instruments.

APAs are categories of regulated Data Reporting Services Providers (“DRSPs”) within the EU and the UK under the MiFID II/MiFIR regulatory framework.[1]

An “APA” means an Approved Publication Arrangement which provides the service of publishing post trade reports (continaining the price volume and time of transactions concluded in financial instruments) in real time, or near to real time[2], by regulated investment firms pursuant to Title III, Articles 20 & 21 of MiFIR. In this way APAs provide a public record of TOTV instruments traded over-the-counter (OTC) in the relevant jurisdiction and such data can play an important role in price formation for such instruments.

The APAs exist to provide regulatory services to clients in respect of post trade transparency and transaction reporting in financial instruments in each jurisdiction. In the UK, APAs are regulated by the UK FCA, and in the EU, the major APAs are directly regulated by ESMA[3].

[1] APA services are regulated under the Markets in Financial Instruments Directive (MiFID II) and Markets in Financial Instruments Regulation (MiFIR) regulatory framework, as supplemented by secondary legislation. As part of the UK Government Brexit legislation, the UK onshored the MiFID II/MiFIR regulatory framework into UK law with UK-specific modifications. All references in this FAQ document to MiFID II or MIFIR include references to the onshored equivalent in the UK.

[2] Subject to deferrals per asset class and applicable law.

[3] Under a certain trade count and volume threshold, derogated APAs are regulated by national competent authorities and not ESMA.

Post implementation of MiFID II/MiFIR, the body of law and expertise in relation to trade and transaction reporting has grown and is under near constant review and scrutiny in both the EU and the UK. The aim of APAA is to harness the expertise of the providers of APA services in the EU and the UK. Since the event of Brexit and the subsequent divergence of laws between the EU and UK financial markets, the members of APAA have an important role to play to bridge the dialogue between EU and UK regulators and policymakers to help facilitate common solutions for the global market participants who access the EU and UK markets.

The APAA is uniquely placed to represent common APA interests in relation to regulations and laws impacting trade and transaction reporting and the associated supervisory framework, and to promote dialogue with policy makers, regulators and market participants in furtherance of the regulatory agendas and for the good of the market.

Importantly, the existence of the APAA is designed to ensure there is a trade association for APA providers to communicate with all relevant stakeholders including regulators, policy makers and industry, wherever such views are aligned. The APAA was formed to maximise efficiency of communication between the members and all their stakeholders and to overcome mutual challenges in trade and transaction reporting for the long-term benefit of the EU and UK financial markets and the end investors.

The APAA will focus on applying the considerable combined expertise of its members to support the regulatory agenda in the EU and the UK, identifying common methods and strategies to improve the quality of financial market transaction data and its auditability, and supporting the adoption of workable common standards in trade and transaction reporting with a view to reducing costs to the end investors, and ultimately improving the capital market structures in both the EU and the UK.

The APAA has three main aims:

  • To develop and support the adoption of best practice in order to improve the quality and consistency of data reported to regulators.
  • To assist authorities and regulators with advice on practicalities related to implementing laws.
  • To promote an efficient market infrastructure by supporting dialogue with market participants, policymakers, regulators and APAA members.

Collectively, APAA members have a vast amount of institutional expertise in managing complex data sets and improving data quality and transparency. The APAA is therefore well-positioned to act as an interface between market participants, regulators and policymakers to help efficiently drive standards to the ultimate benefit of the end investor.

The APAA’s current members and APA affiliates are:

EU DRSPs UK DRSPs
Bloomberg Data Reporting Services B.V (APA)

Cboe Europe B.V. (APA)

MarketAxess Post-Trade B.V. (APA)

Tradeweb EU B.V. (APA)

Nasdaq Nordic (APA)

UnaVista TRADEcho B.V. (APA)

Bloomberg Data Reporting Services Limited (APA)

Cboe Europe Limited (APA)

London Stock Exchange plc (APA)

MarketAxess Post-Trade Limited (APA)

Tradeweb Europe Limited (APA)

Membership of the APAA is open to EU and UK operators of an APA supervised by either the FCA or ESMA. The APAA does not represent EU DRSPs subject to derogation from ESMA supervision.

For more information, including membership enquiries, please email contact@apa-association.org.

The APAA is established as an unincorporated association and all the members have adhered to a common constitution.

The association’s activities are governed by members of the APAA’s Executive Committee, who are responsible for the executive management of the association. The APAA has appointed David Bullen to act as Secretary-General to manage its affairs.

The APAA would like to highlight the following issues that are of interest to members of the association:

  • Data quality: APAA members would like to help regulators in the EU and the UK to develop practical and efficient solutions to resolving issues with data quality.
  • Regulators: APA members are interested in working with regulators in the EU and the UK to provide industry expertise and shape regulation within the applicable regulatory framework.

CONTACT

contact@apa-association.org

David Bullen
Secretary General
The APA Association (APAA)
C/o MarketAxess Post Trade Services BV

Keizersgracht 264, 1016 EV, Amsterdam, Netherlands