MS23/1: Wholesale data market study: benchmarks, credit ratings data and market data vendors

Terms of reference & market study notice
Deadline for stakeholder views
Deadline for stakeholder views on the update report
Market study report

On 29 February 2024 we published our market study report.  

We have published our Wholesale Data market study report alongside the non-confidential responses to our Terms of Reference and Update report. The report highlights our findings about competition for credit ratings data, benchmarks and market data vendor services.

Read MS23/1.5 Report (PDF) 

Our findings

Overall, we have not found evidence that firms cannot access the wholesale data they need. However, across all 3 markets in scope of the study, we have identified evidence of, and drivers for, market power. This means that users may be paying higher prices for the data they buy than if competition was working more effectively.

Our market study

We launched this market study in March 2023 to investigate persistent user concerns about how wholesale data markets are working. We looked at benchmarks, credit ratings data and market data vendor (MDV) services. As set out in the terms of reference, this study looked at 6 cross-cutting themes:

  • barriers to entry and expansion
  • network effects
  • vertical integration
  • suppliers’ commercial practices
  • data users’ behaviour
  • incentives for innovation

Next steps

We have identified several areas where more effective competition could be encouraged in wholesale data markets to improve outcomes. We will focus our next steps on two broad areas – looking at where the issues identified could be addressed through the Smarter Regulatory Framework and tackling firm specific issues using other tools such as our powers under the Competition Act 1998

Following the introduction of the Government’s Smarter Regulatory Framework, we have begun a substantial programme to review our regulatory framework in wholesale markets. This package of regulatory reform involves multi-year projects which are considering a wide range of topics.

Our scope to make changes to existing regulatory requirements may be increased as the Treasury reviews the regulations relevant for wholesale data markets. We will use the findings of this market study to inform potential changes to these regulations that could help address the issues we have identified.

As we consider we are in a strong position to lead on shaping a holistic and proportionate approach to tackle these issues, we will not be making a market investigation reference to the Competition and Markets Authority


Wholesale data plays an important role in wholesale financial markets. When wholesale data markets function well, users of that data can make well-informed decisions on where and how to invest. Effective investment decisions are essential for economic growth and the UK’s international competitiveness.

This market study is part of our wider work on wholesale data. This includes our trade data review, whose findings and next steps were published alongside the launch of the market study. This market study also informs our ongoing work on developing consolidated tapes for bonds (due to start operating in 2025) and equities.

Market Study – Annexes

Annex 1: Financial Analysis (PDF)   

Annex 2: Benchmarks (PDF)   

Annex 3: Credit Ratings Data (PDF) 

Annex 4: Market Data Vendor (PDF)