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29. ESMA’s objective in setting standards for venue execution quality data is therefore to facilitate TCAbased on consistent data and calculation methodologies rather than to prescribe particular benchmarks.However, a sample of potential benchmarks is included in the Annex to this chapter as contextfor this Discussion Paper, and to provide an opportunity for respondents to comment on whetherESMA should specify methodologies for use in calculating any of these benchmarks.30. ESMA recognises that the data included in standardised venue disclosures is only of value to theextent that it can be acted on by investors or their agents. Investment firms are currently required toconduct a review of their best execution policies whenever a material change occurs that affects theirability to continue to obtain the best possible result for the execution of its client orders on a consistentbasis using the venues included in its execution policy.31. Increasing the frequency of data reporting may increase how frequently firms need to review theirexecution policies. Both the publication of venue execution quality data and the administrative burdenon firms of acting on it needs to be properly calibrated so that it is proportionate. But the obligationto review execution policies and arrangements where there has been a material change is alreadyin place and execution quality data will merely be another source of information for firms to consideras part of their on-going monitoring processes.32. The MiFID Implementing Directive states that “a review [of the execution policy] shall […] be carriedout whenever a material change occurs that affects the firm's ability to continue to obtain the bestpossible result for the execution of its client orders”. ESMA considers that the investment firm shouldtake the publication of the data envisaged in this Discussion Paper into consideration, in order to determinewhether they represent a “material change” which requires that they review their executionpolicy.Q27: Would increasing the frequency of venue execution quality data generate additionalcosts for you? Would these costs arise as a result of an increase of the frequencyof the review, or because this review will require additional training foryour staff in order to be able to analyse and take into account these data? Pleaseprovide an estimate of these costs.Q28: Do you agree that investment firms should take the publication of the data envisagedin this Discussion Paper into consideration, in order to determine whetherthey represent a “material change”?33