Brussels, 6 January 2020 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to contribute to the ESMA consultation paper on the MiFID II review report on position limits and position management in commodity derivatives. Europex has actively participated in previous MiFID related consultations, such as the call for evidence on position limits that took place last summer. While the review fulfils a legal obligation under MiFID II, this exercise is also a vital opportunity to assess the impact of position limits and position management on commodity derivatives markets and to ensure the regime is working in practice
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Archives for Consultation Responses
Europex response to the ESMA consultation on the review of the Market Abuse Regulation (MAR)
Brussels, 29 November 2019 | Europex, the Association of European Energy Exchanges, welcomes the initiation of the MAR review and would like to use this opportunity to underline the importance of the MAR policy objectives. A robust and coherent regulatory framework to combat market abuse is necessary to help safeguard the integrity of financial markets and provide clarity to market participants as well as market infrastructure providers. A number of principles underpin our response to this review, including the need to ensure coherence between MAR and other pieces of legislation such as the Benchmarks Regulation (BMR) and the Regulation on
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Tax challenges of the digitalisation of the economy: Joint EFET-Europex response to OECD public consultation on the “Secretariat Proposal for a “Unified Approach” under Pillar One”
Amsterdam/Brussels, 12 November 2019 | The European Federation of Energy Traders (EFET) and the Association of European Energy Exchanges (Europex) support the general objective of the OECD in securing a global consensus over a fair taxation of the digital economy and welcome the opportunity to comment on the scope of the initiative. In this context, we are concerned that a too broadly defined scope of the unified taxation approach of the OECD proposal will lead to a situation where certain digital financial services will unintentionally fall under the new tax. Concretely, the current wording of the scope (page 7, section
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Europex response to the ACER Public Consultation on the Bridge Beyond 2025
Brussels, 9 September 2019 | Europex welcomes the opportunity to contribute to the present consultation. Below, we provide comments on selected aspects thereof. To facilitate the discussion, we use the same topic headings as proposed in the consultation document. Targeted regulation and market functioning 1. Is the proposed response set out above appropriate to address the challenges the sector faces? What should be done differently and why? In particular: 1a. For monitoring the GTM metrics and prompting action, should the threshold values be set out at EU level? What should they be? Who should set these values? 1b. Should there
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Europex response to the consultation on the draft Delegated Regulation adjusting the EU ETS auction process for 2021-30
Brussels, 6 August 2019 | Europex welcomes the opportunity to comment on the proposal for a Commission Delegated Regulation to align the auctioning of allowances with the EU ETS rules for the Fourth Trading Period and with the classification of allowances as financial instruments as published on 9 July 2019. In this context, we have taken particular positive note of the following suggested changes: ▪ The simplified procedure for the determination and publication of auction calendars; ▪ The clarification of rules on the distribution of auction volumes in case of multiple auction cancellations; ▪ The clarification of the notification procedure for
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Consultation response: methodology for a co-optimised allocation process of cross zonal capacity for the exchange of balancing capacity or sharing of reserves
Brussels, 30 July 2019 | Europex is pleased to contribute to the consultation on the ‘All TSOs’ proposal for a methodology for a co-optimised allocation process of cross zonal capacity for the exchange of balancing capacity or sharing of reserves in accordance with Article 40 EB GL.’ The primary parts of the response are included below. Please add here your feedback related to Articles 1 and 2 ‘Subject matter and scope’ and ‘Definitions and interpretation’ Europex fully supports the use of market-based mechanisms to ensure the most efficient allocation of cross-zonal capacity, in particular in the day-ahead, intraday and balancing
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Joint consultation response on the future of emissions trading in the UK
12 July 2019 | EFET, the Federation of European Energy Traders, and Europex, the Association of European Energy Exchanges welcome the opportunity to take part in the present consultation on the future of emissions trading in the UK, launched by the Department for Business, Energy and Industrial Strategy (BEIS). Importantly, we would like to highlight that the basic principles of continuity and predictability of carbon pricing are key for preserving well-functioning electricity, gas and emissions markets in the United Kingdom. The prevailing uncertainty about the continued participation of the UK in the EU ETS post-Brexit, and about the way in
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Europex response to the EC Targeted Consultation for the Evaluation of the Guidelines on State Aid for Environmental Protection and Energy 2014-2020 (EEAG)
Brussels, 10 July 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to respond to the European Commission’s consultation in the context of the Evaluation of the Guidelines on State Aid for Environmental Protection and Energy 2014-2020. Europex supports theEuropean Commission’s goal to bring the guidelines in line with new electricity market developments and to ensure the market integration of renewables, a stable regulatory framework for investments in renewables and a cost-efficient achievement of the set renewable targets. It is worth recalling that power exchanges are increasingly central to the cost-efficient integration of renewable energy sources in
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Europex response to the ESMA call for evidence on position limits in commodity derivatives
Brussels, 5 July 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to contribute to the ESMA call for evidence on position limits and position management in commodity derivatives. Europex has actively participated in previous public consultations on the MiFID II/MiFIR package, including on the position limit regime as well as on its implementing legislation and the related regulatory guidance. The present call for evidence offers an important opportunity to review the regime 18 months after its entry into application. Importantly, Europex supports the policy objectives of MiFID II/MiFIR to ensure transparency and prevent abuse in commodities
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Europex response to the CEER Public Consultation on Regulatory Challenges for a Sustainable Gas Sector
Brussels, 17 May 2019 | Europex is pleased to contribute to the present consultation on a sustainable gas sector and welcomes the associated stakeholder dialogue. We are convinced that gas will continue to play an important role in the future energy mix as a flexible source of energy, able to compensate for the growing share of intermittent renewable sources and to act as a large-scale energy carrier. In view of the EU’s 2030 and 2050 climate and energy goals, it is clear that the gas sector will have toundergo a transformation process and that renewable and decarbonised gases will play
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