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minimum standard to constitute taking “all sufficient steps to obtain, when executing orders, the bestpossible result for their clients”.23. ESMA considers it important to ensure that the implementation cost of this obligation is proportionateto its potential benefit to market participants. Since monitoring is already a regulatory obligation,ESMA considers that the implementation costs of publication should be minimal when comparedwith the alternative of developing a bespoke regulatory reporting product, which may be of more limiteduse. Firms could, if they chose to do so, publish their full internal monitoring without the additionaltime and expense involved in preparing a summary.24. In addition, ESMA considers that there would be clear benefits to enhanced transparency over theways in which investment firms identify and correct deficiencies, or consider changes to their executionarrangements (as required under Article 27(7) of MiFID II). Increasing transparency in this crucialarea would be fully consistent with the overall objectives of MiFID II and would also reflect recentsupervisory experience by Member States, that the quality of investment firm monitoring of executionquality is not consistently good.25. Recent ESMA work also indicated that the level of client awareness of best execution is not high, andthat, as a result, there is little challenge by clients of how firms ensure best execution. Publication ofmonitoring would increase awareness of a client’s right to request demonstration that their own ordershave been executed in line with an investment firm’s execution policy. This is fully in line withother enhancements to Article 27 of MiFID II, which focus on improving the adequacy of disclosureand information to clients.26. ESMA is mindful that there may be distinct challenges related to an assessment of execution qualityin relation to ‘directed orders’ for which the client assumes some degree of responsibility as a result ofhaving given specific instructions to an investment firm. It would be neither fair nor useful for summaryinformation on execution quality to capture decisions for which an investment firm is itself notresponsible.27. While MiFID II is clear that best execution continues to apply to those aspects of an order not coveredby specific instructions, it could be a very complex task to establish a clear perimeter of responsibilityfor order execution in a summary report. For example, the simplest specific instruction could bewhere clients have selected a particular execution venue.28. Other instructions may also be relevant, including the use of specific performance benchmarks.However, ESMA considers that in the case of performance benchmarks that are specified by the client,the investment firm is still responsible for achieving the best possible result (and not merely theminimum standard specified in the benchmark), such that it would still be relevant to capture informationon execution quality where a particular benchmark has been set.29. In considering minimum standards for publication of firms’ own monitoring, ESMA considers thatinvestment firms would need to demonstrate that:monitoring included information on execution quality in respect of each class of financial instru-ment for which the firm executed client orders in the preceding year;i.ii.their published monitoring is based on a representative sample of client orders;41