The Multilateral Single-Dealer System - An Oxymoron under MiFID II?

22 Pages Posted: 13 Sep 2017 Last revised: 21 Sep 2017

Date Written: September 13, 2017


Among European regulators and in the academic literature diverging criteria have been developed to distinguish multilateral from bilateral trading systems. Depending on which criteria are applied, operators of multilateral systems may or may not organise multilateral trading in the form of a (quote-driven) single-dealer system. This article is meant to present our position on this issue. We argue that the wording of the second sentence of recital 7 of MiFIR (Regulation (EU) No 600/2014) disguises the true legal intention of MiFID II/MiFIR, which, at a minimum, allows market operators to structure a regulated market as a single-dealer system.

Keywords: Stock Exchange, Regulated Market, Single-Dealer Systems, Market Maker, Multilateral, Bilateral

JEL Classification: G23, G28, K22

Suggested Citation

Kumpan, Christoph and Müller-Lankow, Hendrik, The Multilateral Single-Dealer System - An Oxymoron under MiFID II? (September 13, 2017). Available at SSRN: or

Christoph Kumpan (Contact Author)

Bucerius Law School ( email )

Jungiusstr. 6
Hamburg, 20355

Hendrik Müller-Lankow

Independent ( email )

Frankfurt a. M.

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