How to Compare Forex and Crypto Fill Quality

Your fill is the product

When you place a trade through a broker or platform, you don't buy a currency pair the way you buy a bag of rice. You buy a promise: that the price you get is a fair one, arrived at honestly, with the costs you were told about and no invisible extras. That promise is what "execution quality" means. It's a mouthful of a phrase for something simple — did you get a good deal, and can you tell?

The trouble is, you usually can't tell from a single trade. One fill is a coin toss in a fast market. Fill quality only becomes visible in patterns: across many orders, across quiet and chaotic days, across the moment you clicked and the moment you were filled. That's why regulators invented reporting — so that the pattern is written down somewhere you can look at it, instead of being locked inside the firm's own systems.

What Europe tried: RTS 27 and RTS 28

Under Europe's MiFID II rulebook — the region's framework for how investment firms treat clients — two reporting standards arrived in 2018. They had wonderfully forgettable names.

RTS 27 put the duty on trading venues and execution venues: publish free, public, quarterly data on execution quality, covering price, costs, speed and likelihood of execution for individual financial instruments. In plain terms, the venues had to show their homework, and anyone could download it.

RTS 28 put the duty on the firm handling your order: publish an annual report naming the top five venues it used for each class of instrument, plus a summary of the execution outcomes it achieved. The idea was that you could line up two brokers' reports and see who routed your orders somewhere better.

It was a noble idea, and it largely didn't work. A regulator's own review found these reports were "rarely read" and didn't let investors or anyone else make meaningful comparisons from the information provided. If a disclosure is technically published but practically unreadable, it's a bit like a restaurant posting its hygiene rating in a locked cabinet. The EU suspended RTS 27 reporting for two years from 2021, then dropped it entirely as part of its MiFID II review. On RTS 28, the European Securities and Markets Authority told national regulators in February 2024 not to prioritise enforcement while the new rules were still being written into national law.

Two lessons sit here. First, transparency rules can fail on usability rather than on principle. Second, the underlying obligation never left — best execution still stands, and regulators still expect firms to monitor it. Only the paperwork changed shape.

The US approach: ask, and you'll receive

Across the Atlantic, the National Futures Association — the self-regulatory body for US retail forex — took a different route, with less publishing and more on-demand access.

Under NFA rules, a retail forex customer can request transaction data for a specific executed trade, and the dealer must respond within 30 minutes. The reply covers the 15 trades in the same currency pair immediately before and after yours, with execution date and time to the nearest millisecond, your side of the trade, quantity, currency pair, execution price including any mark-up, and commissions or other charges. There's a sensible boundary: the dealer only has to supply data for trades within 15 minutes either side of yours. And crucially, the dealer must tell you this right exists, prominently, on its website, its trading platform, and your confirmation statements — not buried in a document nobody opens.

That's a genuinely useful design. Instead of hoping you'll parse a quarterly data file, it lets you ask one sharp question: was my price fair compared with what was happening around me at that moment?

What else a US forex dealer must show you

NFA rules layer on other disclosures that make fill quality legible. On each trade confirmation, dealers must show commissions and other fees. If the dealer uses straight-through processing — automatically passing your order to an offsetting position with another counterparty, with no human intervention — it must disclose any mark-up or mark-down it applies between the price it received and the price you got. If it doesn't use straight-through processing, it must disclose the mid-point spread cost: the gap between your execution price and the midpoint of the bid-offer spread at the moment your order arrived.

Separately, dealers must publish annual disclosure on their websites covering their business activities, the liquidity providers and prime brokers they use, their risk management approach, capital levels, and any material enforcement actions in the past three years. They must also prominently display the required risk disclosure for each of the most recent four calendar quarters in which they held retail customer accounts.

Where crypto sits — and it's messier

Here's the honest part: none of the frameworks described above were written with crypto in mind. Crypto venues sit in a patchwork of national regimes, and many jurisdictions have no equivalent of RTS 27, RTS 28, or the NFA transaction-data request. Where rules do apply, they depend entirely on where the venue is licensed, what it's licensed as, and whether it serves retail or professional clients. Some crypto platforms publish execution statistics voluntarily; some publish none. This is exactly the kind of area where the jurisdiction you're in, and the jurisdiction the venue claims, both matter — and where a licensing logo tells you less than you'd hope.

What a careful reader can actually do

You don't need to be an analyst. You need three habits.

First, find your firm's execution policy. Under MiFID II, firms must explain clearly, in detail and in a way clients can understand, how orders will be executed — and get your prior consent to that policy. If it reads like it was translated twice, that's information too. Firms must also notify you of material changes to their execution arrangements if you have an ongoing relationship, and review those arrangements regularly to check the venues still deliver the best possible result.

Second, notice what "best" means. Best execution isn't "best price" alone. It's the best possible result measured in total consideration — the price of the instrument plus every cost directly tied to execution, including venue fees, clearing and settlement fees, and other third-party charges. A slightly better headline price with heavier surrounding costs may not be better at all.

Third, if you're in the US retail forex market, use the request. Ask for the surrounding trades on a fill you didn't like. It's a legitimate, rule-backed question, and the answer arrives fast.

Watch the direction of travel

The broader lesson from the European experiment is that disclosure rules get retired when they're technically compliant but practically useless. That doesn't mean transparency lost — it means the requirement moved from publishing data at you to monitoring and demonstrating quality. The burden shifted from the reader's eyes to the firm's evidence.

For you, that's a mixed blessing. Fewer quarterly files to ignore. Also fewer quarterly files to consult. The things worth checking now are the policy, the confirmation statement, the annual website disclosure, and — in the US — the answer to a direct question. None of that tells you what tomorrow's fill will look like. Nothing does. But it tells you whether the firm is willing to be looked at.