Matched monetary definitions put settlements at 42.5% of 2025 pecuniary sanctions. Two €7.4m German fines explain almost 42% of that settlement value, showing how a few decisions shape the aggregate.
Parsing MiFIR Article 39a and ESMA’s German transitional notice defines which order-flow payments fell within the temporary exemption and why a German licence alone did not cover foreign-domiciled clients.
Reconstructing the October fee schedule reveals an 83% step at one non-display usage threshold, plus fixed differences between redistribution categories. The calculation concerns published list prices, not an across-the-board price increase.
Reproducing the report-once cost model shows how one imputed input drives its weighted benefit. The model also leaves the full staged transition unpriced; the result is a sensitivity finding, not a rejection of reform.
The Dutch policy makes incident detection and voluntary notification central to enforcement. Percentage thresholds mean smaller reporting operations can also fall within its scope.
The 15 October update connects derivatives identification with public trade data and explains routes for tick-size intervention. Brokers face separate questions about data preparation and venue price increments.