Brussels, 25 April 2018 |The purpose of the present paper is to provide ESMA and all interested National Competent Authorities (NCAs) with detailed information in support of their work in amending specific aspects of ‘RTS 2’ in relation to the MiFIR pre-trade transparency regime for non-equity instruments. Europex members have long argued that the MiFIR pre-trade transparency regime does not apply to trade registration. We consider that the regime in its present form is not fit for purpose and cannot be applied to trade registration facilities in energy derivatives markets without compromising their vital role in supporting the hedging activity
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