The MiFID II RTS 28 Report Nobody Reads — What It Actually Tells You About Your Broker

Buried in the legal section of every MiFID II-regulated broker's website is a document called the RTS 28 report. It is the single most useful piece of execution-quality disclosure produced by retail forex brokers in the EU — and it is read by approximately nobody. This piece explains what RTS 28 is, what to look for, and which EU brokers publish disclosures worth the byte count.

What RTS 28 actually is

Regulatory Technical Standard 28, published by ESMA under Article 27 of MiFID II and in force since 2018, requires every authorised investment firm operating on behalf of clients to publish, on an annual basis, the top five execution venues used during the previous calendar year, broken down by client class and instrument type. The disclosure must include:

- The top five execution venues by traded volume for each MiFID II instrument class (FX CFDs, equity CFDs, commodity CFDs, etc.) - The percentage of orders executed at each venue - The percentage of orders that were passive (rest on book) versus aggressive (cross the spread) - The percentage that were directed orders (client specified the venue) - A summary explanation of the broker's order-routing logic and how it achieved best execution under the relevant factors (price, cost, speed, likelihood of execution and settlement)

The report is mandatory. The deadline is 30 April for the prior calendar year. Failure to publish is an enforceable breach under MiFID II and can trigger a CySEC, BaFin, or AMF enforcement action.

Why nobody reads it

Three reasons:

**It is buried.** Most broker websites file RTS 28 under "Legal Documents" or "Best Execution Policy" in the footer, alongside PDFs nobody opens. The retail-facing surface of the website never references the disclosure directly.

**It is dense.** A typical RTS 28 PDF is 6-25 pages of tables, footnotes and regulatory language. It is written for a regulator audience, not a retail trader audience.

**Nobody has told retail clients what to look for.** Education sites cover the standard MiFID II protections — segregated funds, negative balance protection, ICF compensation — but rarely mention RTS 28. The result is that the most useful document the broker is forced to publish is the one no client ever opens.

What an RTS 28 report actually tells you

Three signals worth extracting from any RTS 28 disclosure:

1. Concentration of execution venues

A broker that routes 95% of EUR/USD orders to a single venue is operating a tightly-controlled (often single-LP) execution model. This can be efficient or it can be a sign that the broker has commercial reasons to favour one venue. A broker that distributes orders across 5+ venues with weights of 15-30% each is operating a multi-LP aggregation model where competition between LPs tightens spreads.

Neither is intrinsically better, but they signal different broker types. A multi-LP aggregator is typically running an ECN/STP model. A single-venue router is more often running an internalised market-making model — fills against its own book.

2. Passive vs aggressive order split

The RTS 28 disclosure breaks executions into "passive" (orders that sat on the order book waiting for a counterparty) and "aggressive" (orders that crossed the spread to execute immediately). For a retail broker, almost all client orders are aggressive — clients want immediate fills. A retail-focused broker showing 95-100% aggressive execution is being honest.

A broker showing significant passive execution on retail accounts is doing something unusual — either it is running limit-order strategies on behalf of internalised accounts, or its definition of "aggressive" is loose. Worth probing.

3. The narrative section

Every RTS 28 report includes a summary section explaining the broker's order-routing logic. This is the part worth reading carefully. A strong narrative will explain:

- How the broker selects its LP panel and how often the panel is reviewed - How the broker monitors execution quality (latency, fill ratio, slippage statistics) - How the broker treats large orders that cannot be filled at a single price - How the broker handles partial fills on illiquid instruments - How the broker resolves conflicts between price improvement and execution speed for different client types

A weak narrative will use standard MiFID II language without specifics — "we monitor execution quality on a continuous basis using industry-standard metrics" — and tell you nothing about how the broker actually operates.

EU brokers that publish solid RTS 28 disclosures

Based on review of the 2025 reports (filed April 2026) of every broker we cover:

**[Pepperstone](/brokers/pepperstone)** publishes one of the better RTS 28 disclosures in the EU-regulated retail forex sector. The 2025 report (for the Cyprus entity, CySEC 388/20) lists 7 named LPs for major FX with weighted concentration figures, includes a slippage statistics summary by instrument class, and describes the latency-monitoring infrastructure in technical detail. The narrative section runs 4 pages and describes how the LP panel was rotated in 2025.

**[IC Markets](/brokers/ic-markets)** publishes a strong CySEC-entity disclosure (CySEC 362/18) with venue concentration, passive/aggressive split, and a clear best-execution policy. The slippage statistics are reported separately to the RTS 28 filing but accessible from the same Legal Documents page.

**[Tickmill](/brokers/tickmill)** publishes a CySEC RTS 28 disclosure with named LPs and a strong narrative section. The 2025 report is one of the more readable in the sector and explicitly addresses how the broker handles symmetric vs asymmetric slippage.

The common feature across the brokers above is that the disclosure reads as if it were produced for retail clients who might actually look at it, not solely for regulators. The narrative sections are specific. The data is broken down at a level that lets a client draw real conclusions.

EU brokers whose RTS 28 disclosure is weaker

Without naming specific firms in pure negative terms — there is no enforcement action to point to in either case — two pattern types are worth flagging:

**Brokers that file the disclosure as a single-page PDF with venue names redacted as "Liquidity Provider 1, Liquidity Provider 2".** This is technically compliant with the letter of RTS 28 but useless to a reader. There is no enforcement action and the practice is not formally prohibited, but the absence of named venues is itself a signal — a broker that is comfortable with the relationship will name the LP.

**Brokers whose RTS 28 disclosure does not include slippage statistics or a meaningful narrative section.** The report runs to 4-6 pages of tables with no explanation of how the broker monitors execution quality. The broker is meeting the minimum compliance bar without communicating anything useful. A broker with strong execution typically wants the reader to know it. A broker with weak execution prefers the reader to skim.

We will not name brokers in the second category in this piece. The structural rule on this site is that we name brokers when we can support the criticism with a verifiable specific (a regulator enforcement action, a documented client complaint pattern, a quantitative gap in published data). RTS 28 weakness is suggestive but not damning on its own. The reader can compare any broker's published RTS 28 PDF against the criteria above and draw their own conclusions.

How to actually read an RTS 28 disclosure

A 4-step process for anyone looking at one for the first time:

1. **Find the broker's "Best Execution Policy" or "Legal Documents" page.** RTS 28 disclosures live there. If you cannot find the disclosure within 90 seconds of landing on the broker's homepage, that itself is a signal. 2. **Skip to the FX CFD section.** Most retail forex traders care about the FX category, not equity or commodity CFDs. The venue table for FX is typically the first or second table in the disclosure. 3. **Count named venues and read the concentration percentages.** Are venues named or anonymised? Is the top venue 35% or 95% of volume? Single-venue concentration warrants the broker explaining why. 4. **Read the narrative section in full.** This is where the broker explains its order-routing logic. If the narrative section is two paragraphs of MiFID II boilerplate, the broker is not communicating. If the narrative section runs three pages and describes specific monitoring and review processes, the broker is taking the disclosure seriously.

What we use RTS 28 for in our methodology

Our [methodology](/methodology) scores execution quality partly on whether the broker publishes a strong RTS 28 disclosure. A broker scoring at the top of our execution component will have:

- A current-year RTS 28 PDF accessible from the homepage in fewer than 3 clicks - Named execution venues with explicit concentration percentages - A passive/aggressive split that matches the broker's stated business model - A narrative section that describes specific best-execution monitoring infrastructure - Slippage statistics either embedded in the RTS 28 or accessible from the same legal-documents surface

A broker that meets all five gets a strong execution score. A broker that meets three of five gets a mid-tier score. A broker that meets one of five gets flagged for additional verification before we list it in our editorial rankings.

What clients should actually do

If you are choosing a forex broker, three minutes spent on the broker's RTS 28 disclosure is more useful than thirty minutes spent on the broker's marketing page. The disclosure is one of the few pieces of broker-published content where there are clear, comparable, mandatory data points. Use it.

For the per-broker reviews on this site we link to each broker's most recent RTS 28 disclosure directly from the review page. The 2025 reports for the brokers we cover are all current as of May 2026 — the next filing cycle is April 2027.

For wider context on EU regulation of retail forex brokers see our [/questions/what-is-cysec](/questions/what-is-cysec) and [/questions/what-is-bafin](/questions/what-is-bafin) explainers.

The RTS 27 sibling — what changed in 2021

A brief technical note for completeness. The MiFID II Article 27 disclosure regime originally consisted of two RTSs:

- **RTS 27** — execution-venue-level disclosure (quarterly), where the venue (the broker acting as execution venue, or the upstream LP) discloses its own execution quality on a per-instrument basis. - **RTS 28** — investment-firm-level disclosure (annual), where the firm discloses its top execution venues used.

In 2021 the European Commission, responding to industry feedback that RTS 27 disclosures had low utility and high preparation cost, suspended RTS 27 reporting via the MiFID Quick Fix Directive (Directive (EU) 2021/338). The suspension was confirmed and extended through subsequent ESMA statements. RTS 28 remained in force.

The consequence for retail traders is that the only currently-mandatory execution-quality disclosure under MiFID II is the annual RTS 28 filing. The quarterly venue-level RTS 27 disclosures that supplemented it from 2018-2020 are no longer required. This makes the annual RTS 28 disclosure even more important as a signal — it is the only formal disclosure of execution-quality information that retail clients can routinely access.

ESMA has periodically signalled it is reviewing the MiFID II execution-disclosure regime as part of the broader MiFIR Review. A reformed regime may be introduced post-2026 that re-instates some form of venue-level disclosure. The current status (as of May 2026) is RTS 28 only.

What an RTS 28 disclosure cannot do for you

Three honest limits on the document:

**It is backward-looking.** The disclosure covers the prior calendar year. Execution quality can degrade between filings. A strong 2025 disclosure does not guarantee strong 2026 execution.

**It is firm-wide.** The disclosure aggregates across all clients of the firm. Your individual execution experience may diverge from the firm-wide aggregate if you trade at unusual sizes, in illiquid pairs, or during volatile sessions. The aggregate disclosure is a signal about the broker's typical performance, not a guarantee about your specific orders.

**It is self-reported.** While the data is regulator-mandated and the firm is liable for false reporting under MiFID II, there is no independent audit of the slippage figures or the LP-concentration percentages. The disclosure is a credible signal because the regulator could pull the firm's records, but it is not third-party verified.

These caveats matter for interpretation. A strong RTS 28 disclosure is a positive signal but not a guarantee. A weak RTS 28 disclosure is a meaningful negative signal — a broker that cannot make a strong disclosure when the regulatory framework provides the opportunity to do so has revealed something about its underlying execution quality or its priorities.

How RTS 28 interacts with the broker's wider best-execution policy

MiFID II requires every authorised firm to maintain a documented Best Execution Policy describing how it achieves best execution for client orders. The Best Execution Policy is a longer, more narrative document than the RTS 28 disclosure. It typically covers:

- The execution factors the broker considers (price, cost, speed, likelihood of execution and settlement, size, nature of the order) - The relative importance the broker assigns to each factor for each instrument class and client type - The execution venues the broker considers and the criteria for selecting them - The arrangements the broker has in place to monitor and review execution quality - The arrangements for handling specific instructions from clients (when the client specifies a venue or rejects the broker's default routing)

The Best Execution Policy is the where the broker explains its philosophy. The RTS 28 disclosure is where the broker reveals the operational outcomes of that philosophy. Reading both together is more informative than reading either alone. A broker whose Best Execution Policy states a multi-LP aggregated approach should show a distributed venue concentration in the RTS 28 disclosure. A broker whose Best Execution Policy describes internal market-making should show concentrated execution at its internal venue. Mismatches between policy and outcome are diagnostic.

For most retail clients, reading the broker's Best Execution Policy in addition to the RTS 28 disclosure is the difference between knowing the broker meets the regulatory minimum and knowing how the broker actually operates.

Risk warning

Trading CFDs and leveraged forex carries a high risk of losing money rapidly due to leverage. Between 74-89% of retail investor accounts lose money when trading CFDs. A broker with a strong RTS 28 disclosure is more likely to give you fair execution but does not change the underlying probability that your strategy is profitable.

*This article reflects RTS 28 disclosures filed in April 2026 for the 2025 calendar year. The next filing cycle is April 2027 for the 2026 calendar year. We re-review every covered broker's RTS 28 disclosure within 30 days of the annual filing deadline.*