Archives for Consultation Responses

Europex Response to the ESMA MiFID II / MiFIR Review Report on the Transparency Regime for Non-Equity Instruments and the Trading Obligation for Derivatives

Brussels, 12 June 2020 | Europex fully supports the objectives of MiFID II / MiFIR and the G-20 Pittsburgh commitments to “improve the functioning and transparency of financial and commodity markets and address excessive commodity price volatility”. We equally agree with the general intention of the MiFIR pre-trade transparency regime which is meant to work towards this larger policy objective. However, we believe the current calibration of the illiquid (“IL”) and Large in Scale (“LIS”) waiver thresholds severely limits the development of niche and nascent contracts traded on secure and transparent exchanges and cleared through risk mitigating CCP clearing houses.
Read More

Europex response to Commission consultation paper for the EU climate ambition for 2030 and for the design of certain climate and energy policies of the European Green Deal

Brussels, 11 June 2020 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to take part in the present consultation. The European Green Deal must be a central pillar of the EU’s recovery efforts in the aftermath of the COVID-19 pandemic and in response to the looming climate and environmental crisis. Against the background of the intended 2030 Climate Target Plan and its subsequent legislative implementation, the opportunity should now be taken to put in place a coherent EU-wide policy framework to deliver the raised emissions reduction ambition at the least cost. With this in mind, it is
Read More

Europex feedback on the Preparation of the EU Hydrogen Strategy

Brussels, 8 June 2020 | Europex welcomes the Commission’s initiative to develop a dedicated EU Hydrogen Strategy. We are convinced that traded markets can and will act as enablers for a future usage of hydrogen on a broader scale, including in those sectors where it still has very limited penetration such as transport, buildings and power generation. Given the importance and complexity of the topic, there should be strong stakeholder involvement in both the development and implementation of the EU Hydrogen Strategy. It is key that the integration of hydrogen into the Internal Energy Market is considered from the beginning
Read More

Europex response to the Commission consultation in preparation of an EU Strategy on Energy System Integration

Brussels, 4 June 2020 | Europex supports a vision of an integrated energy system in which the various energy carriers or forms of energy (electricity, gas, liquids, heat, cold etc.) can be linked with each other as well as with the end use sectors (buildings, mobility, industry, agriculture, households) in order to optimise the energy system as a whole, i.e. producing, transporting and consuming energy in the most sustainable and cost-efficient way possible. To enable this goal, well-functioning energy and environmental markets are required to stimulate competition and innovation, allowing the most efficient technologies to emerge. When developing regulation to
Read More

Europex response to Commission consultation on the review of the MiFID II/MiFIR regulatory framework

Brussels, 18 May 2020 | Europex fully supports the underlying policy objectives of MiFID II / MiFIR and the G-20 Pittsburgh commitments to “improve the functioning and transparency of financial and commodity markets and address excessive commodity price volatility”. However, more than two years after the MiFID II / MiFIR framework started to apply, we believe that these objectives have not yet fully materialised as far as commodity derivatives markets are concerned, notwithstanding the heavy burden already imposed on the industry. This concerns in particular the MiFID II position limits and position management regime as well as the MiFIR pre-trade
Read More

Europex response to the Commission consultation on the priority list for the development of network codes and guidelines on electricity for the period 2020-2023 and on gas for 2020 (and beyond)

Brussels, 14 May 2020 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to take part in the present consultation. Our response addresses the proposed priorities for new electricity network rules on cybersecurity and demand-side flexibility.   Please download the full consultation response below.
Read More

Europex response to ACER consultation on bidding zone review methodology

Brussels, 24 April 2020 | The bidding zone review and resulting decision on the configuration has fundamental consequences for the electricity market in all timeframes. Europex welcomes the opportunity to provide input into ACER’s public consultation on the methodology and assumptions to be used in the bidding zone review process. It is important to ensure that there is robust and transparent analysis supporting both the development of the alternative configurations and their evaluation against the CACM criteria. The assessment of the configuration impact on market efficiency, competition, liquidity and overall welfare must consider both short-term and forward markets, and use
Read More

Europex feedback to Commission 2020 roadmap to fight money laundering and terrorism financing

Brussels, 11 March 2020 | Europex, the Association of European Energy Exchanges, welcomes the Commission’s initiative to review the effectiveness of the existing framework to fight money laundering and financing terrorism. The roadmap sets out important policy objectives  which are also relevant for keeping electricity, gas and emissions trading safe and free of fraudsters who in the past had been associated with money laundering and terrorism financing. In order to continue deterring such behaviour in the future, we would like to use this opportunity to recall the importance of extending the derogation of the domestic reverse charge mechanism (DRCM) for
Read More

Europex response to ESMA consultation paper on MiFID II review report on position limits and position management

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
Read More

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
Read More