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European Venues and Intermediaries Association

EVIA

The European Venues Intermediaries Association promotes enhances the value competitiveness of Wholesale Market Venues, Platforms, Arranging Intermediaries by providing coordination a common voice to foster promote liquid, transparent fair markets.

Lobbying Activity

Response to Revision of the REMIT Implementing Regulation on data reporting

15 Sept 2025

Industry Comments on the inclusion of lifecycle events into OMP Reporting channels for transactions We have real concerns about the proposed changes in connection with OMP reporting of lifecycle events [LCEs]. Our concern is not limited to OMPs alone; implementing the proposed changes will be equally challenging for market participants. In essence, this proposed rule which was never contextualised with OMPs prior its fait accompli presentation by ACER appears to have been conceived with a simple cleared futures exchange model in mind, whereas the heterogeneous panoply of OMPs operate use-case models which are anything but. Thank you for your comments and clarifications on Thursdays ACER Webinar. We are writing as the trade association for Europes broker OMPs to formalise comments made in the discussion concerning the proposals in the draft implementing regulation which require Organised Market Places to report lifecycle events . We add that similar views were expressed to ACER on the prior OMP webinar on 26th June, well before the draft text was finalised; and note that on Thursday, concerned parties were again invited to submit these concerns into this feedback opportunity. We look forward to answering any questions the Commission may have. The implementing regulation sets out that the new requirement for LCEs to be reported by the OMP is, In line with the intentions of the revised REMIT, these changes aim at centralising, as much as possible, the reporting at OMP level, which will, in turn, improve the quality of the data reported to the Agency. The new Article 8 (previously Article 6) provisions for Reporting channels for transactions now contains a paragraph 4 such that: 4. Market participants shall provide the following information to the OMP where the trading occurs: a. information regarding the identity of the intermediate or final beneficiaries of the transaction, if different from the market participant trading on the OMP; b. any information relating to lifecycle events of a transaction that was concluded on the OMP but where the lifecycle event occurred outside the OMP. The information referred to in this paragraph shall be made available to the OMP no later than at the time of reporting as set out in Article 10 and shall be reported to the Agency by the OMP, as part of the OMPs reporting obligation set out in paragraph 1 of this Article. The existing procedures are for market participants to report LCEs directly to RRMs. This is closely analogous to the EMIR requirements for market participants to report LCEs directly to Trade Repositories, or US rules whereby Swap Dealers report LCEs directly to Swap Data Repositories . This approach should continue because after the conclusion of a wholesale energy forward or derivative transaction, the OMP no longer has sight of the trade and the combination of multiple OMPs together with complex trade sets would result in great difficulties reverse engineering trade chains in order to fulfil the rule as provisionally drafted. Essentially, our concerns around LCEs being reported back through OMPs are as follows: All OMPs will need to build and develop completely new systems for reporting lifecycle events to RRMs. All market participants will need to build and develop systems for reporting LCEs to each OMP venue. Given that every OMP is likely to have a different system and process for receiving lifecycle events, market participants will need to develop systems capable of communicating data to all its venues (rather than using a single standard as they do today with RRMs such as Equias and the major exchanges). OMPs will need to create an entirely new infrastructure to handle data relating to LCEs because they will still need to hold data relating to the original transaction. Making changes to the original records would have damaging consequential, knock-on effects meaning a separate and parallel data storage system would need to be created. This provision
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Response to Review of the regulatory framework for investment firms and market operators (MiFID 2.1)

4 Mar 2022

04 March 2022. The members of the European Venues & Intermediaries Association were pleased that the Commission was able to release its MiFID II Review proposals at the end of last year. Having taken the opportunity to review and consider them, EVIA is supportive of several elements which will advance the CMU project and more effectively implement the MiFID II package. In particular: - A consolidated tape lays the tracks for better data and process standardisation across the range of MiFID II financial instruments. - The legislative cleaning up of some of the MiFID “Quick Fix” Covid Measures, especially the comprehensive removal of the convoluted, ill-defined, and under-employed “Best Execution” requirements. - The removed licensing requirements for persons dealing on own account on a trading venue by means of DEA. - The prospective alignment of data standards and reporting obligations between markets regulations and across EU competent authorities. That said, there are a number of areas which we would highlight as concerns: - Stakeholder Input - Trading Venue Perimeter – Definition of a “Multilateral Trading System” - Trading Venue Perimeter – Limitation of the OTF to Non-Equities - Consolidated Tape – Pre-Trade Transparency - Consolidated Tape: Revenue Model Means Expropriation without Compensation - Consolidated Tape: “Reasonable Commercial Basis” for Data Costs - Consolidated Tape: Inefficient and Ineffective Structure - Consolidated Tape: Failure to Remove the Hurdles and Barriers Hampering Derivatives Transparency - Derivatives Trading Obligation – Application to Certain Firms - Derivatives Trading Obligation – Suspension of the Clearing Obligation - Payment for Order Flow (PFOF) - Double Volume Cap - Reference Price Waiver These matters are considered in detail in the attached letter. Please do not hesitate to respond with any queries or questions you may have.
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