Response to ESMA Consultation on Guidelines for Non-Significant Benchmarks

Overall, FESE agrees with the draft guidelines on non-significant benchmarks published by ESMA, however, in terms of the scope of input data further clarification is necessary.

Data from regulated trading venues (within and outside the EU) should be considered regulated data and trading venues should not be considered contributors.

Moreover, FESE considers it important that a proportionate approach is selected since the guidelines will apply to non-significant benchmarks.