Published:
FESE agrees with most of ESMA’s proposals. Notably, the proposal to extend the requirements to set, review and report accountability levels to trading venues offering derivatives on emission allowances, and the proposal to harmonise the unit of reporting for certain contracts.
As a general comment, FESE wishes to stress that it supported the conclusions from the 2020 ESMA report on the MiFID II Review on position limits and position management, which reinforced the changes that were subsequently introduced in the MiFID “quick fix”. These changes made commodity derivative markets much more efficient and flexible. As such, we do not see a need for bigger changes in the way position limits and position management controls work apart from those included in this ESMA consultation paper. The system is currently working as intended.