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

Categories: Consultation Responses.

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
Read More

Categories: Position Papers.

Europex response to the BMF consultation on MiFID II experiences

Brussels, 15 March 2019 | Europex, the Association of European Energy Exchanges, welcomes the opportunity to contribute to the present consultation on MiFID II / MiFIR experiences1. In the following, we would like to share our concerns on three main aspects: 1) pre-trade transparency requirements for commodity derivatives, 2) position limits for commodity derivatives and 3) the scope of the hedging exemption in relation to the previous two points. 1) Pre-trade transparency requirements for commodity derivatives (MiFIR, Arts. 8 & 9) Europex members have long argued that the MiFIR pre-trade transparency regime in its present form is not fit for purpose
Read More

Categories: Consultation Responses.

MiFIR pre-trade transparency regime: making it work for commodity derivatives – recommendations

Brussels, 25 June 2018 | The purpose of this paper is to provide ESMA and National Competent Authorities with specific recommendations in support of their work with regard to amending certain parts of Regulation 2017/583 (‘RTS 2’)1, relating to the MiFIR pre-trade transparency regime for non- equity products. Europex members have long argued that, in its present form, the regime is not fit for purpose and cannot be applied to trade registration facilities in energy derivatives markets. Should these pre- arranged trades be no longer reported to regulated markets for clearing purposes, this would compromise their vital role in supporting
Read More

Categories: Position Papers.

The MiFIR pre-trade transparency regime: making it work for commodity derivatives

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
Read More

Categories: Position Papers.