I have a post up on FSMLabs web site about the use of GPS and other satellite time for MiFID II timestamp compliance. It’s fascinating how much effort has recently gone into trying to convince people that MiFID II will require direct time from a national lab or certified via a national lab despite the clear wording in MiFID II proposed regulations. To me, the deal is sealed in the Cost Benefit Analysis in which the ESMA regulators write
“The final draft RTS also reduces costs of the initial draft RTS proposed in the CP by allowing UTC disseminated via satellite systems (i.e. GPS receiver or the use of other satellite systems when available)”
That is not a promise one can easily walk away from. ESMA justifies the regulations with a cost/benefit analysis in which the costs for time stamping are limited by license to use GPS time. Of course, legal reasoning and logic are not always the same, but I’m trying to figure out how ESMA regulators could claim that they didn’t mean it, or why they would have such a motivation.