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 transparency rules – both which we fully support in their spirit. However, we consider that their current calibration prevents any substantial increase in volumes traded on exchanges and cleared through CCP clearing houses, which would ensure a high level of security and transparency for these transactions.

We therefore consider it crucial that this review exercise is done with a view to ensure that the legislative framework becomes fit for purpose and supports the creation of an efficient high-quality ecosystem for energy commodity trading that fosters sustainable economic growth – notably in light of the new political, economic and climate reality.

Please download the full consultation response below.