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COBS 11.4 Client limit orders

Obligation to make unexecuted client limit orders public

COBS 11.4.1RRP

Unless a client expressly instructs otherwise, a firm must, in the case of a client limit order in respect of shares admitted to trading on a regulated market which is not immediately executed under prevailing market conditions, take measures to facilitate the earliest possible execution of that order by making public immediately that client limit order in a manner which is easily accessible to other market participants.

[Note: article 22(2) of MiFID]

COBS 11.4.2GRP

In respect of transactions executed between eligible counterparties, the obligation to disclose client limit orders should only apply where the counterparty is explicitly sending a limit order to a firm for its execution.

[Note: recital 42 to MiFID]

How client limit orders may be made public


An investment firm shall be considered to disclose client limit orders that are not immediately executable if it transmits the order to a regulated market or MTF that operates an order book trading system, or ensures that the order is made public and can be easily executed as soon as market conditions allow.

[Note: article 31 of MiFID Regulation]

COBS 11.4.4GRP

MAR 5.8.2 EU sets out the conditions required for an arrangement to make client limit orders1 public under this section. MAR 5.8.3 G and MAR 5.8.4 G provide guidance on these conditions.1

Orders that are large in scale

COBS 11.4.5RRP

The obligation to make public a limit order will not apply to a limit order that is large in scale compared with normal market size.

[Note: article 22(2) of MiFID]

COBS 11.4.6GRP

MAR 5.7.10 EU and MAR 5.7.11 EU set out when an order shall be considered large in scale compared with normal market size.