FESE Response to the ESMA Consultation on Settlement discipline

While FESE does not comment on the specific operational needs of CSDs, it highlights that their opening hours are closely linked to those of trading venues and CCPs, which in turn reflect national market practices. Harmonising CSD business day schedules across the EU would risk overlooking these local specificities.

Given the move to T+1, the “daily” operational timetable should continue to accommodate late trading cut-offs currently in place, which align well with the business needs of various market participants. To support this, enhancements in post-trade processes may be necessary. The key objective is to ensure that all on-exchange trades from day T are included in the first T2S night-time settlement cycle, optimising settlement efficiency.