Archives for Position Papers

MiFIR Pre-Trade Transparency: Call for a Methodology for the Conversion of LIS Notional Values to Lots

Brussels, 15 July 2019 | Europex and its members are committed to working with ESMA and the NCAs to ensure that markets continue to become more transparent in line with the policy objectives of MiFID II/MiFIR. In this context, we take note of the recently published “ESMA Supervisory Briefing on compliance with MiFIR pre-trade transparency requirements in commodity derivatives” and welcome ESMA’s commitment to review the currently inappropriately calibrated pre-trade transparency regime. As stated at earlier occasions, the enforcement of full compliance should be postponed until after the review of RTS 2 as otherwise irreparable damages would be caused to
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The “Road from Sibiu”: making use of markets for a cost-efficient and innovation-driven transition to full climate neutrality by 2050

Brussels, 9 May 2019 | Today, a long and intense debate on the “Future of Europe” that started two years ago in Rome comes to a close at a European Council summit in Sibiu. One of the key topics of this strategic exchange has been Europe’s future climate and energy policy, notably with regard to the EU’s Clean Planet for All strategy and the overall United Nations Framework Convention on Climate Change process. In this context, we call upon the European leaders gathered today in Sibiu to keep up with their Paris commitments and to include a strong recognition of
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Article 13 (9) of the Electricity Regulation: The basic implementation phase for reconfigured bidding zones should be 24 instead of 12 months

Brussels, 8 November 2018 | Ensuring bidding zones are configured efficiently is necessary in order to address long-term structural congestion. However, any change to the configuration of bidding zones has a fundamental impact on the functioning of wholesale electricity markets. While the change itself, once implemented, may bring about overall benefits the transition process itself comes at a cost which is ultimately passed on to the electricity consumers. In order to minimise this cost and to leave the market enough time to adapt, the implementation phase needs to be appropriate and must guarantee a smooth transition. Recent experience has shown
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Capacity allocation in Article 14 of the Electricity Regulation recast: Setting the right principles to maximise transmission capacity available for trading in order to foster further market integration

Brussels, 8 November 2018 | In the EU’s internal energy market, the amount of trade between bidding zones is constrained by the amount of available cross-zonal transmission capacity. Maximising the amount of the cross-zonal capacity available to the market, while respecting necessary operational security standards, is therefore a prerequisite for achieving an efficient integrated internal energy market and realising the associated increase in welfare. In this context, the process to calculate and allocate capacity on the bidding zone borders is vitally important. However, there is significant scope to improve the current situation. The ACER 2017 Market Monitoring Report (MMR) compared
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Electricity market design – Europex positions on the Electricity Regulation, Electricity Directive and the ACER Regulation

Brussels, 11 October 2018 | The trilogue negotiations for the electricity market design files (the draft recasts of the Electricity Regulation, Electricity Directive and ACER Regulation) are well under way. At this stage it is crucial that all parties can agree on workable solutions grounded in market realities. Overall, this is an opportunity to ensure that wholesale markets are efficient, accessible and are ready to meet the challenges of the energy transition. This paper raises five aspects emerging from the negotiations so far which we believe are necessary to address or maintain. A comparison of the positions of the Commission,
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Common energy sector statement – Keeping EU energy and emissions markets protected from VAT fraud beyond 2018

Urgent need to confirm the extension of the derogation for a domestic reverse charge mechanism for electricity, gas and emission allowances in Art. 199a of the VAT Directive Brussels, 4 September 2018 | Missing Trader Intra-Community Value Added Tax fraud remains a persistent threat to the integrity and well-functioning of electricity, gas and emission allowance markets in Europe. Billions of euros had been defrauded from European Exchequers before the Council of the EU decided on the introduction of a derogation from the VAT Directive for electricity, gas and emission allowance transactions. The derogation enables Member States to apply the Domestic
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The Essential Tasks of Third Party Market Operators/Facilitators in the Electricity Market (update)

Brussels, 16 August 2018 (updated)| In a number of EU Member States/EEA countries, certain functions related to the operation of the electricity market, which are necessary for the electricity market to work efficiently, are carried out by non-TSO third parties rather than by TSOs. These third parties, also called “Third Party Market Operators/Facilitators”or“Delegated Operators”, and the vital roles they play,are recognised in the European Network Codes and Guidelines. The tasks performed by these third parties include, among others, imbalance calculation and settlement, data publication related to electricity balancing markets and issuing of the rules related to balancing markets. These tasks
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Europex reactions to the CEER study on the Future Role of Gas

Brussels, 25 June 2018 | Europex welcomes the initiative from the Council of European Energy Regulators (CEER) to explore the Future Role of Gas (FROG) as well as its implications for the regulatory framework and infrastructure requirements. We share the view that gas plays a very significant role in Europe’s energy mix today and will continue to do so in the mid- and long-term. A variety of energy sources, including natural and renewable gas, will be required to meet the EU’s long-term objectives of secure, affordable and clean energy for all Europeans. Natural gas offers many advantages as a flexible
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Europex recommendations ahead of the electricity market design trilogues

Brussels, 18 June 2018 | In this document, Europex provides its recommendations ahead of the electricity market design trilogues, with a focus on the Electricity Regulation and Directive. We make our recommendations in the form of a four-column table, allowing comparison between the positions of the Commission, Parliament and Council on key topics. In some instances we support the position of one of the institutions, in others we make more specific proposals. Europex believes that a continued focus on strong market principles is necessary during these important trilogue negotiations. This market design will be relevant well into the 2020s so it
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Europex supports EMIR Refit but calls for deletion of Amendment 4 in line with the overall intention to simplify and streamline

Brussels, 19 March 2018 |Europex strongly supports the EMIR Refit process and welcomes the ECON draft report as well as the intended simplification of reporting obligations and improvement of data quality. We especially value the aim to achieve a reduction of costs for market participants and to extend the possibilities of choice for clearing members. However, we are highly concerned about Amendment 4 as tabled on 26 January 2018 in the Langen draft report. We fear that the amendment, which states that: ‘The CCP should report to the TR specified by the counterparty. Clearing members and their clients should be
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