Federation of European Securities Exchanges

FESE welcomes the European Commissions Call for Evidence on the Digital Simplification Omnibus initiative. We support the Commissions simplification agenda and its efforts to streamline digital rules in order to reduce administrative costs for businesses, citizens, and public administrations.

FESE supports the plan of the European Commission in proposing an overarching data strategy that has the potential to achieve the benefits of the single market. To this end, we believe a harmonised European approach is preferable to speed up the use/investment in technologies while effectiveness, fairness, proportionality, the international competitiveness of the EU market, and the safety of its people should be a…

FESE members organise markets dedicated to sustainable finance and offer products that contribute to sustainable development, facilitate management of climate risk and incorporate carbon reduction in investment strategies, as well as allow the tracking of sustainable companies’ performance. Moreover, FESE members actively engage in the UN Sustainable Stock Exchanges initiative to promote sustainable capital markets.

FESE members organise markets dedicated to sustainable finance and offer products that contribute to sustainable development, facilitate management of climate risk and incorporate carbon reduction in investment strategies, as well as allow the tracking of sustainable companies’ performance. Moreover, FESE members actively engage in the UN Sustainable Stock Exchanges initiative to promote sustainable capital markets.

From the FESE perspective, we observe several overlaps between sector-specific legislation such as DORA and horizontal regulation such as the NIS 2 Directive and the Cyber Resilience Act. Our longstanding position is to support the use of DORA as the reference framework for ICT security in the financial sector, and we therefore welcome recital 16, which recognises that DORA constitutes lex specialis to the NIS…

Increasing retail investors’ access to capital markets will be vital if Europe is to secure a sustainable recovery. Europe needs to empower retail investors by making investment practices simple(r), cheaper, transparent, and by taking steps to prevent conflicts of interest.

Please find attached the Federation of European Securities Exchanges (FESE)s submission to this Commissions Have Your Say. It outlines FESEs key considerations on the trading and digital elements of the Commissions proposal on the Market Integration & Supervision Package (MISP), while FESE continues its work on other aspects of the proposal.

The Federation of European Securities Exchanges (FESE) believes that the success of the Savings and Investments Union (SIU), critical to addressing the persistent gap between Europes economic potential and its actual performance, will depend on progress across three interconnected pillars of EU capital markets: 1. stimulating investment and expanding capital pools; 2.

FESE supports the Commissions simplification and burden reduction agenda, as well as its commitment to streamlining regulatory obligations and reducing compliance costs for the industry. In light of these objectives, the current language for the introduction of position reporting arrangements in REMIT for certain commodity derivatives, known as exposure reporting, raises significant concerns.

FESE very much welcomes the proposed Delegated Act on SME Research. We share the Commission’s expectation that exempting small and mid-cap companies from the unbundling rule should result in an increase of research coverage for those companies.

The Benchmarks Regulation (BMR) applies to all benchmarks regardless of the underlying market. However, we believe different types of benchmarks pose different types of risks to the markets. From a global perspective – where many developments have taken place – IOSCO has recognised that benchmarks based on regulated data could be subject to a proportionate approach.

FESE very much welcomes the removal of the open-access provisions for exchange-traded derivatives, the prohibition of payment for order flow, and the removal of the exception to the exemption from authorization as investment firm for DEA users, which together will make markets stronger. However, some points deserve further reflection: 1.