RTS 25: Clock Synchronisation
Bats operates with gateway-to-gateway latency of less than one millisecond. This leads, under MiFID II, to a synchronisation requirement of at least one microsecond granularity and up to one hundred microseconds divergence from UTC. It is expected that the majority of Bats participants will require transaction timestamping at a similar precision. Bats has been engaged with FIX Protocol Limited's (FPL) regulatory sub-committee on Clock Synchronisation and notes the recommendation to introduce microsecond capabilities on relevant FIX messages and back-port this to FIX 4.2. Bats provides an opt-in feature to send microsecond level data to customers using the method recommended by FPL. Please contact our Trade Desk to have this enabled. Prior to the MiFID II implementation date, this will change to be an opt-out feature.
Where firms need only millisecond level granularity, Bats supports the industry standard approach of truncating the timestamp to the granularity required.
Bats has produced an outline position paper and a reference architecture for consideration by firms. Bats recognises that the Clock Synchronisation requirement is not a requirement to have a real time computing infrastructure, but rather one that attempts to allow accurate alignment of events at a macro level across Europe. We recognise that there are multiple approaches to establishing a system of traceability to UTC, of which our approach is just one. With a documented and consistent approach to the matter, the overarching goals of the regulators can be met, without undue burden on the industry.