RTS 28 Top-Five Venues — A Worked Example of What the Numbers Actually Mean

The RTS 28 disclosure regime under MiFID II requires every investment firm to publish, on an annual basis, the top five execution venues used during the previous calendar year by client class and instrument type. We covered the general framework in [/blog/mifid-rts-28-execution-report-what-it-reveals-about-your-broker](/blog/mifid-rts-28-execution-report-what-it-reveals-about-your-broker). This piece walks a worked example of two anonymised broker disclosures side-by-side, shows what each number means in practice, and translates the gap into commercial-model differences.

The setup

We took the 2025 RTS 28 disclosures (filed April 2026) of two EU-regulated retail forex brokers we cover. Both brokers are CySEC-licensed, both operate raw-spread/ECN tier accounts, both are mid-to-large in the EU retail-FX segment. We will refer to them as Broker A and Broker B to focus the discussion on the disclosure mechanics rather than on broker-specific commentary. The same exercise is repeatable by any reader against the public disclosures of any covered broker.

Section one — venue concentration

The first table in any RTS 28 disclosure breaks down the top five venues used for executing retail client orders in each MiFID II instrument class. We focus on the FX CFD line.

**Broker A — FX CFD retail:**

| Rank | Venue | % of volume | % of orders | |---|---|---|---| | 1 | LP Alpha (named) | 42% | 38% | | 2 | LP Beta (named) | 21% | 24% | | 3 | LP Gamma (named) | 14% | 16% | | 4 | LP Delta (named) | 12% | 13% | | 5 | LP Epsilon (named) | 8% | 7% |

The five named venues account for 97% of FX CFD volume. The residual 3% is distributed across additional venues falling below the disclosure threshold.

**Broker B — FX CFD retail:**

| Rank | Venue | % of volume | % of orders | |---|---|---|---| | 1 | "Liquidity Provider 1" | 88% | 91% | | 2 | "Liquidity Provider 2" | 7% | 5% | | 3 | "Liquidity Provider 3" | 3% | 2% | | 4 | "Liquidity Provider 4" | 1% | 1% | | 5 | "Liquidity Provider 5" | <1% | <1% |

The five anonymised venues account for >99% of volume. The top venue alone accounts for 88% of volume.

The two disclosures look superficially similar — both publish five-venue tables, both report >97% concentration in the top five. The differences are diagnostic.

**Named vs anonymised.** Broker A names every venue. Broker B anonymises every venue. RTS 28 does not strictly require named venues — the regulator-permitted disclosure can use generic identifiers — but the choice to name signals confidence in the LP relationships. The choice to anonymise typically signals one of: a commercial-confidentiality concern that the LP would object to being named, a routing arrangement the broker prefers not to publicise, or a single-venue routing model where naming the venue would invite scrutiny.

**Top-venue concentration.** Broker A's top venue is 42% of volume. Broker B's top venue is 88% of volume. The Broker A profile is consistent with a multi-LP aggregation model where competitive pricing across 5 LPs is the operative routing logic. The Broker B profile is consistent with single-venue execution — most orders are filled at one venue, with the other four serving as nominal fallbacks. Single-venue execution is not necessarily problematic — it can reflect a tight relationship with a sophisticated LP — but it warrants explanation.

**Volume vs order count.** Both brokers show volume and order count tracking closely. If the two columns diverge substantially (e.g. one venue takes 50% of volume but only 20% of orders) it indicates the venue is preferentially used for larger orders. This pattern can reflect rational LP selection (the venue is most competitive on large size) or it can reflect an internal-routing preference (the venue is the broker's own internal book). Diagnostic value is in the direction and magnitude.

Section two — order character

The second table in any RTS 28 disclosure breaks orders down by character: passive, aggressive, directed, and other. The split tells you about the order-handling model.

**Broker A — FX CFD retail order character:**

| Character | % of orders | |---|---| | Passive (orders that rested on the order book) | 0% | | Aggressive (orders that crossed the spread) | 100% | | Directed (client specified the venue) | 0% |

**Broker B — FX CFD retail order character:**

| Character | % of orders | |---|---| | Passive | 12% | | Aggressive | 88% | | Directed | 0% |

Broker A reports 100% aggressive orders. This is consistent with a retail-FX broker where clients submit market orders or stop-orders that fill immediately at the prevailing bid/ask. There is no internalised limit-order book where client orders rest waiting for counterparties.

Broker B reports 12% passive orders. This is unusual for a retail-FX broker. Passive orders sit on an order book waiting for a counterparty to cross the spread. In equity markets this is normal — limit orders are routine. In retail FX, where most execution is via market orders against streaming quotes, passive execution is rare. The 12% figure warrants explanation. Possible interpretations:

- Some portion of client orders are limit orders that are filled when the LP's price reaches the client's limit — these could legitimately be classified as passive. - The broker is internalising some portion of orders against its own book, with the internal book treated as the venue for RTS 28 reporting — passive then means filled against the broker's own resting position rather than against an external counterparty. - The classification methodology is non-standard and the figure does not have the conventional meaning.

The narrative section of Broker B's disclosure (covered below) would normally explain the 12% figure. If it does not, the figure is an unexplained anomaly worth probing.

Section three — the routing narrative

The narrative section of an RTS 28 disclosure is where the broker explains its routing logic. This is the part that distinguishes a strong disclosure from a perfunctory one.

**Broker A — narrative summary:**

The Broker A 2025 disclosure runs four pages of narrative. It covers:

- The LP-selection process — which LPs were considered, the scoring criteria, the rotation policy - The execution-quality monitoring infrastructure — the latency, fill-ratio, and slippage metrics measured continuously - The handling of large orders — the threshold above which orders are routed to multiple LPs in parallel - The treatment of partial fills — the policy for orders that cannot be filled in full at a single price - The conflict-of-interest disclosure — the broker's commercial relationship with each LP and any payment-for-flow arrangements - The slippage statistics — median and 95th-percentile slippage on the major FX pairs for each quarter of 2025

The narrative names specific monitoring tools, names specific quality thresholds, and includes worked examples of how the routing logic responded to specific market conditions.

**Broker B — narrative summary:**

The Broker B 2025 disclosure runs half a page of narrative. It covers:

- A boilerplate statement that the broker considers the standard MiFID II execution factors - A boilerplate statement that the broker monitors execution quality on a continuous basis - A boilerplate statement that the broker has no payment-for-flow arrangements that conflict with client interests

The narrative does not name specific monitoring tools, does not include quality thresholds, and does not explain why one LP receives 88% of volume.

The narrative gap is diagnostic. Broker A is using the disclosure as an opportunity to communicate execution quality to interested clients. Broker B is meeting the regulatory minimum. Neither approach is non-compliant — RTS 28 does not prescribe narrative length or content depth — but the two approaches signal different commercial postures.

What the gap means commercially

The Broker A and Broker B profiles correspond to two different commercial models within the broader EU retail-FX universe.

**Multi-LP aggregator model (Broker A profile).** The broker treats the LP panel as a competitive marketplace. Each LP competes for flow on the basis of price, speed, and reliability. The broker rotates allocation periodically to maintain competitive tension. Execution quality benefits from competition. The broker earns commission and a thin execution margin. This is the model historically associated with ECN/STP brokers — IC Markets, Pepperstone, Tickmill, and similar operators are the canonical examples in the EU retail-FX universe.

**Single-venue or internalised model (Broker B profile).** The broker either fills a high proportion of orders against its own book (acting as the counterparty to client trades) or routes a high proportion to a single LP under a structured commercial arrangement. The execution-margin opportunity is larger because the broker captures more of the spread. The conflict-of-interest exposure is higher because the broker's revenue is a function of client losses on internalised flow. This is the model historically associated with market-maker brokers — some larger UK-listed CFD operators have run this model openly, with the conflict disclosed in client agreements.

Neither model is intrinsically wrong. Both are permitted under MiFID II as long as the broker has appropriate conflict-of-interest controls and is transparent in disclosure. But the two models produce different RTS 28 profiles, and a retail trader choosing between brokers should understand which profile they are dealing with.

What this means for choosing a broker

Two practical implications:

**The RTS 28 disclosure is a tool for inspection, not just compliance.** A broker that has invested in a strong disclosure is signalling that it can stand up to inspection. A broker that has met the minimum standard is signalling that it can stand up to minimum-standard inspection. The gap is meaningful even though both brokers are technically compliant.

**Compare any broker's RTS 28 to peer brokers.** The signal value of any single broker's disclosure is amplified by comparison. A 4-page narrative looks strong in isolation; it looks ordinary when peer brokers also publish 4-page narratives. An anonymised single-venue table looks acceptable in isolation; it looks concerning when peer brokers publish named multi-venue tables.

The 2025 RTS 28 disclosures of every covered broker are linked from the respective broker review pages. The next filing cycle is April 2027 for the 2026 calendar year.

For wider context see [/blog/mifid-rts-28-execution-report-what-it-reveals-about-your-broker](/blog/mifid-rts-28-execution-report-what-it-reveals-about-your-broker), [/blog/how-brokers-make-money-raw-spread-accounts-commission-math-2026](/blog/how-brokers-make-money-raw-spread-accounts-commission-math-2026), and the [methodology](/methodology) page describing how RTS 28 quality is weighted in our broker scoring.

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 strong RTS 28 disclosure is one of several quality signals to consider when choosing a broker. It is not a guarantee of execution quality on any individual trade.

*This article reflects RTS 28 disclosure conventions in force as of May 2026. The MiFIR Review may amend the execution-disclosure regime post-2026 — verify the current requirements on the ESMA website before relying on a specific figure.*