This response has been compiled by EACH, EFET, Eurelectric, Eurogas and Europex and reflects the views of their respective memberships
We do not agree with the view that a system where on one side of any trade (buy side or sell side) there is always the same party should be considered multilateral simply because the system is operated by a third party (draft ESMA opinion no. 24).
Europex is fully aligned with the core objectives of the Principles to ensure that commodity derivatives markets can serve their fundamental role of facilitating fair and efficient price discovery and hedging in a transparent, secure and well-regulated trading environment, while remaining free from market manipulation and other abusive practices.
We support ACER’s approach to delete Article 59(5) of the proposal, which proposes a cap on remuneration of LTTRs in case of fallback allocation. We do not see adequate justification to extend the HAR Article 59 compensation caps to LTTR remuneration during decoupling events.
We welcome the opportunity to provide feedback to ESMA’s draft proposals for the review of RTS 21 and ITS 4 as well as the proposal for new technical standards for position management controls. Europex’ members have gained extensive experience with the implementation of the MiFID II position limit regime and position management provisions.
Europex welcomes the opportunity to provide feedback to the Commission’s public consultation on the draft delegated act for amending the ancillary activity exemption (AAE) in
Europex welcomes the opportunity to provide feedback to this draft delegated regulation. While the current proposal for the Union Renewable Development Platform (URDP) is designed
We see benefit in adding the emission allowances to the definition of financial instruments in the FCD, making it also more closely aligned to the financial instruments definition in Annex 2 of Directive 2014/65/EU (MiFID II).
Europex welcomes the opportunity to contribute to the present consultation. In our response, we highlight that the regime on VAT rules for financial services subject
Europex supports the Commission’s overall objective to ensure a fair taxation of the digital economy in Europe in line with the wider policy objectives set
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