MIFID 2 Review – Market Structure: EBF priorities

EBF adviser: Pauline Guérin

Publication date: 08 July 2021

General Comments:

Below a few points, the EBF and its members underline:

• The EBF is a true supporter of the EC Capital Markets Union Action Plan and the ambition to further integrate capital markets in the EU. We therefore welcome a review of MiFID II/MiFIR that is aimed at facilitating issuers’ and end-clients’ use of EU capital markets for the purposes of their financing and risk management.


• The EBF supports both multilateral and bilateral trading models to co-exist since they serve different functions and needs. As far as equity transparency is concerned, EBF supports not to restrict end-clients’ access to different types of execution venues such as Sis and to revise the double volume cap system (DVC) in consideration of Brexit.


• Considering the specificities of bonds and derivatives markets, the EBF supports a revision of the deferral regime while keeping the SSTI thresholds for Sis.


• The EBF is particularly worried by the rise of market data costs since 2007.


• The EBF agrees that a properly constructed Consolidated Tape (CT) could bring benefits to the EU capital markets such as consolidated information and increased transparency.

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MIFID 2 Review – Market Structure: EBF priorities