[ESMA 70-872942901-35 MiFIR transparency Q&A, Q&A 4.4]

a) How is the requirement for a package order that ‘Each component of the transactions bears meaningful economic or financial risk related to all the other components’ to be interpreted?
b) Can package orders also include equity instruments? If yes, how is pre- and post-trade transparency applied?
c) When does an investment firm apply the systematic internaliser obligations on a package order level?
d) How should systematic internalisers determine whether package orders which are not liquid as a whole are subject to the transparency obligations in non-equity instruments under Article 18(1) or 18(2) of MiFIR?
e) Which party to a package transaction is required to make the transactions public via an APA?
f) Can package orders (Article 2(1)(49)(b) of MiFIR) also include instruments that are not admitted to trading or traded on a venue?
g) Where an investment firm buys a newly issued bond in the primary market as the result of an allocation and funds its investment by selling another bond to the lead manager of the issuance, simultaneously with and contingent upon the investment in the new issue, would this qualify as a package order for the purpose of pre-trade transparency?

In the gas derivatives market, lot sizes defined in the contract specification by trading venues do not represent a standard quantity of the underlying across all market areas, for the same maturity. How should the open interest in lots be calculated for gas derivatives, for the application of position limits in Article 57(1) of MiFID II?

Does Article 19(12a) of MAR require issuers to expressly allow their PDMRs to trade during a closed period in the case of transactions or trade activities that do not relate to active investment decisions, that result exclusively from external factors or actions of third parties, or that are based on predetermined terms?

Related to the definition provided by the Regulation, what are the criteria that can be used to identify the continuity component (i.e "on ongoing basis) mentioned?

Are Crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024 and which are authorised to continue to do so under the law of a Member State in accordance with Article 143 of MiCA, considered to be crypto-asset service providers under the terms of MICA during the transitional period until they are authorised?