Archives for Consultation Responses

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
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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.
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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
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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
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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
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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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