Tag: gps

ESMA clarifies time sources for MiFID II

Post author By vy
Post date January 7, 2016

ESMA just released guidelines that reinforce what was already clear in the MiFIDII regulation – that GPS time is a perfectly acceptable source of “traceable” time. There is a lot else that is of interest in this report, but it’s a good reminder to not be panicked by marketing scare-tactics.

As per Article 1 of the MiFIR RTS 25, systems that provide direct traceability to the UTC time issued and maintained by a timing centre listed in the BIPM Annual Report on Time Activities are considered as acceptable to record reportable events. The use of the time source of the U.S. Global Positioning System (GPS) or any other global navigation satellite system such as the Russian GLONASS or European Galileo satellite system when it becomes operational is also acceptable to record reportable events. GPS time is different to UTC. However, the GPS time message also includes an offset from UTC (the leap seconds) and this offset should be combined with the GPS timestamp to provide a UTC timestamp.

Tags gps, traceable time

business timekeeper

MiFID II, GPS and UTC time

Post author By vy
Post date November 24, 2015

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.