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quality data and the venues that investment firms are actually choosing to use. It is essential that theinformation provided by the investment firms is easily understandable and comparable, therefore thehighest possible degree of standardisation should be pursued in relation to information on where investmentfirms route their orders.10. ESMA considers that the timeframe for reports should be the same for all firms. For instance, annualreports should include data from the previous civil year or with reference to fixed quarters (1 Januaryto 31 March, 1 April to 30 June, 1 July to 30 September and 1 October to 31 December). The reportsshould be published, at most, one month after the end of the relevant period, once again to allow forcomparability and also timeliness. Such standardised reference periods and publication delay are requiredto facilitate comparison.11. ESMA considers that in order to allow clients to compare the data of different investment firms whenevaluating the quality of execution they provide, the investment firms should publish the data relatingto their execution of orders with regard to a uniform reference period, with a minimum of specific reportingdetails and in a compatible format of data based on a homogeneous calculation method.Q34: Do you agree that the investment firms should publish the data relating to theirexecution of orders with regard to a uniform reference period, with a minimumof specific reporting details and in a compatible format of data based on a homogeneouscalculation method? If not, please state why.Q35: What would be an acceptable delay for publication to provide the clients with usefuldata?Q36: What format should the report take? Should there be any difference depending onthe nature of the execution venues (MTF, OTF, Regulated Market, systematic internalisers,own account) and, if so, could you specify the precise data requiredfor each type?Investment firm execution quality12. Unlike order flow reporting, which would benefit from harmonisation to allow for ready comparison,standardised measures of execution quality for investment firms are less easy to develop given therole played by client instructions, order type and a range of other factors in assessing performance.13. For instance, many clients (particularly more sophisticated buy-side firms) will give very detailedinstructions and will often specify the performance benchmark to the investment firm executing theirorders. Common measures might be to set a participation rate, aim to achieve the volume weightedaverage price (VWAP) over a trading day or the time-weighted average price (TWAP) for a specifiedperiod.14. More sophisticated approaches can be taken to minimise the implementation shortfall of a givenexecution (the difference between the theoretical value of an order when received by the executing investmentfirm versus the value of the subsequent execution), which take account of explicit executioncosts and also the implicit costs related either to the market impact of the execution or the opportunitycost of not executing.15. This is an area of considerable complexity and investment firms, their clients and third party consultantscontinue to develop algorithms to optimise and assess execution performance. For this reason,39