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International Capital Market Association

ICMA

ICMA promotes efficient cross-border capital markets to fund sustainable economic growth, representing over 600 members across 70 countries including banks, asset managers, and market infrastructure providers.

Lobbying Activity

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque)

20 Jan 2026 · Discussion on the upcoming regulatory and supervisory priorities concerning the European Capital Markets

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

20 Jan 2026 · Savings and Investments Union (SIU), bonds markets, Market Integration Package (MIP)

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

28 Oct 2025 · SFDR Review

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Banco Santander, S.A.

3 Jul 2025 · Challenges for the EU repo market in relation to the forthcoming move to a shorter settlement cycle (T+1)

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque)

23 Jun 2025 · Settlement regime

Meeting with Emiliano Tornese (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

11 Jun 2025 · AMIC Steering Committee where the Commission was invited to discuss and exchange views on the macroprudential policy agenda for NBFIs and the SIU Consultation

ICMA urges permanent lower stable funding costs for banks

10 Mar 2025
Topic — EU consultation on amending bank funding rules for securities financing transactions.
Message — ICMA advocates for making permanent the current lower funding requirements for short-term transactions. They request swift action or transitional measures before the June 2025 deadline to avoid market distortions.12
Why — Permanent lower requirements prevent a funding cost spike and maintain international competitiveness.34
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Response to Savings and Investments Union

7 Mar 2025

ICMA welcomes the opportunity to provide a response to the European Commissions (EC of the Commission) Call for Evidence regarding the establishment of the Savings and Investment Union (SIU) published on their website on 3 February 2025. This paper combines new insights with recent and previous contributions and how they pertain to the ECs SIU plans launched at the outset of their new five-year mandate 2024-2029. The EU needs investment to fund its economic growth, support its competitiveness globally, and address challenges such as climate change, digital transition, and pensions for an ageing society. Cross-border capital markets development will be critical in achieving this. These policy objectives have been outlined e.g. in previous EC Calls for Evidence and communications related to the Capital Markets Union (CMU), confirmed by many EU authorities, including the European Central Bank (ECB). Bond markets have a vital role to play in supporting many of these priorities, particularly in providing the debt finance that EU-based companies and institutions need as part of their overall funding requirements to grow and innovate, as well creating investable instruments for EU citizens. Bond markets also help to rebalance the current reliance on banks, which in the EU remain the primary source of corporate funding through loans and the principal channel for individuals to deploy their savings in the form of deposits. EU citizens can benefit by shifting appropriate parts of their savings into capital, and especially bond markets, as these provide steady income, lower risks compared to other financial instruments and allow investors to diversify their capital. Bond markets are a fundamental component of capital markets, providing a deep and diverse source of financing for both public and private sector institutions and corporations, whilst offering investors stable returns alongside risk diversification. Broadening and deepening of a truly cross-border EU bond market will be key to the EU meeting the identified challenges ahead and furthering its role as a global economic leader. EU bond markets are already large. The total size of the EU market, including sovereign and corporate debt, is approximately USD25 trillion. This compares to a bond market size of USD53.6 trillion in the United States (US). However, when it comes to corporate bond markets, the EU and the US could not be more different. In the US, 65% of non-financial corporate debt financing is raised through the capital markets. In the euro area, this proportion is relatively small, with 85% of corporate debt depending on bank financing. This potentially limits the availability of debt financing for EU companies and may increase the EU economy's sensitivity to banking challenges. It could also potentially reduce resilience to financial disruptions, as banks' lending capabilities might become more restricted. Furthermore, it reduces the amount and diversity of investible EU financial assets. Further developing pan-European corporate bond markets would not only provide a deeper pool of financing for EU economic investment and growth, but it would help to facilitate the flow of capital across EU borders, thereby reducing barriers to funding access, sharing risk more evenly, and reducing the overall cost of capital for EU corporates and institutions. 7 March 2025
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Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

21 Feb 2025 · Sustainable Finance Disclosure Regulation

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque)

15 Jan 2025 · Upcoming regulatory priorities in capital markets with a focus on fixed income, especially the CMU/SIU and proposals how bond markets can help achieve the EU policy

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

15 Jan 2025 · DG FISMA and ICMA priorities under the new mandate

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

15 Jan 2025 · capital markets

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

14 Jan 2025 · Sustainable Finance Disclosure Regulation

Meeting with Mairead McGuinness (Commissioner)

22 May 2024 · speech on CMU, sustainable finance, digital finance

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

20 Feb 2024 · CMU

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

25 Jan 2024 · CMU, bond market liquidity and resilience

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

21 Nov 2023 · CSDR

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

14 Sept 2023 · listing act, T+1 settlements, clearing

ICMA Urges Protection of Wholesale Bond Markets in Retail Reforms

28 Aug 2023
Topic — European Commission proposals to improve retail investor confidence and participation in capital markets.
Message — The organization requests that the retail investment strategy avoids disrupting institutional markets. They advocate for excluding bonds from product governance rules and clarifying product scope.12
Why — Exempting bonds from governance rules would lower administrative costs for market participants.3
Impact — Professional investors may continue receiving fewer cost disclosures if existing exemptions are preserved.4
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Meeting with Alfred Sant (Member of the European Parliament, Rapporteur)

18 Apr 2023 · Listing Act

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

16 Mar 2023 · CSDR

Response to Facilitating small and medium sized enterprises’ access to capital

13 Mar 2023

Extract from overall ICMA comments on the EU Listing Act proposals (being filed in the context of COM(2022)762): << Listing Directive repeal While the provisions of the Listing Directive are considered to be largely historic and/or redundant, they are understood to underpin certain national listing regimes that would be useful to keep. The Securities Official List (SOL) of the Luxembourg Stock Exchange is based on the Listing Directive. ICMA understands the SOL to be of significant size and distinctly that it is open to admitting distributed ledger technology (DLT) bond issuances, which are not currently eligible for admission to full trading platforms under MiFID. Furthermore, some investors investment mandates are understood to refer to listed securities and so any removal of existing national listing regimes could cause problems in practice. While some market participants consider that the Listing Directive could be repealed, others preference is to leave the Listing Directive as it stands noting that it is not causing problems in practice and there could be unintended consequences if it is amended or repealed. In this respect, ICMA emphasises the need to be very careful in considering any repeal of the Listing Directive in terms of ensuring national listing regimes may subsist (notwithstanding any repeal of the Listing Directive). >>
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Response to Facilitating small and medium sized enterprises’ access to capital

13 Mar 2023

The below is extracted from the attached file of ICMA's full comments. << Prospectus Regulation amendments From the international bond market perspective (over USD 6 trillion raised in bond funding for companies in 2022[*]), the ongoing efficiency of the core regimes[**] of the Prospectus Regulation (PR) are crucial. ICMA is pleased to note these have been mostly maintained, together with some helpful improvements (also touching some of the more specialist regimes[***]) in reducing administrative burdens for issuers (e.g. alleviating the ordering of risk factors, the maximum summary length for guarantors, the language requirements and the process for notifying supplements to investors). However, some further improvements and other points to be aware of are necessary to ensure the prospectus regime amendments truly contribute to the Listing Act policy intentions of reducing administrative burdens to promote European public market activity in the context of CMU. Further detail is set out in the body of [the attached] comment paper. [...] [*] ION Analytics / Dealogic DCM Highlights: FY22. [**] Relating to single document base prospectuses and standalone prospectuses. [***] Relating to tripartite prospectuses (for use also in combination with universal registration documents) and secondary issuance / follow-on prospectuses. >> << Market Abuse Regulation amendments ICMA welcomes the amendments confirming the soundings regime as a voluntary safe harbour from the prohibition on unlawful disclosure of inside information (without prejudice to disclosure of inside information being otherwise lawful as having been made in the normal exercise of an employment, a profession or duties). In this respect, ICMA notes the need for consequent amendment in due course of (i) RTS EU/2016/960 (notably in terms of its Recital 5 and Article 3.4) and (ii) ITS EU/2016/959 (in terms of its Article 2(b) and related Annex II). >>
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

31 Jan 2023 · ICMA’s current priorities and activities.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

31 Jan 2023 · Introductory meeting

Meeting with Paul Tang (Member of the European Parliament, Rapporteur)

25 Jan 2023 · Climate Bonds

Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur)

10 Nov 2022 · Empowering consumers for the green transition

Meeting with Billy Kelleher (Member of the European Parliament, Shadow rapporteur)

21 Jun 2022 · AIFMD

Response to Central securities depositories – review of EU rules

26 May 2022

ICMA and its members broadly welcome the proposed revisions to the CSDR, in particular those relating to the mandatory buy-in (MBI) framework. Members believe that the “two-step approach”, in principle, takes into account the potential disruptive market impacts of applying a mandatory buy-in requirement, as well as allowing for more proportionate and targeted initiatives to improve settlement efficiency rates (including the CSDR penalty regime) to be implemented first. ICMA further welcomes the proposed revisions to the buy-in process, such as providing for symmetrical payments of the buy-in and cash compensation differential and the ability to facilitate pass-ons. ICMA’s members provide three main recommendations to enhance the effectiveness of the proposed revisions which are discussed in further detail in the attached document, along with some more technical refinements, such as amending the regulatory text to address the asymmetry in the cash compensation payment. The document also outlines some considerations for the penalty framework and application from both a secondary and primary market perspective. The first recommendation relates to the assessment process underlying the two-step approach. Here ICMA would suggest that this is not too prescriptive, and a more holistic approach be taken using the outlined criteria. Care will also need to be taken in cross-jurisdictional comparisons, taking into account not only methodology but differences in market structure. Causality (structural versus behavioral) should also be a key consideration. ICMA would further recommend that a recalibration of penalties be an interim step before moving directly to MBIs. In the event that MBIs are deemed appropriate for a particular security or transaction type, adequate time will also need to be provided in order for the industry to prepare for successful implementation, not least in putting in place the extensive, and necessary, contractual arrangements. The second recommendation relates to the reference to securities financing transactions in the Regulation with respect to MBIs. ICMA would argue that buy-ins are an inappropriate and disproportionate remedy for failing SFTs, also raising significant complexities in implementation, as well as legal documentation. SFTs are also widely used to prevent settlement fails, so should be considered as part of the solution, not the problem. ICMA would therefore strongly advocate for the removal of the reference to SFTs in the Regulation. The third recommendation relates to the appropriate regulatory tool for implementing a MBI regime. As ICMA has suggested previously, many of the implementation (and enforceability) challenges related to the CSDR MBI framework stem from the fact that any legal requirements covering a buy-in transaction would be better achieved through market regulation, not post-trade regulation. Buy-ins are not a post-trade process. They are market transactions, executed between trading parties, with associated market risk. In most cases these will not be the CSD “participants” referred to in the Regulation. In other words, what the CSDR MBI framework effectively attempts to do is to impose a requirement for a trading entity to enter into a market transaction through a regulation that does not directly apply to them. In many cases that trading entity will not even be an EU regulated entity. In the event that the Commission determines that an MBI requirement is appropriate for a particular instrument or transaction type in the EU, ICMA would strongly recommend that it apply this through market regulation, targeted at the relevant, regulated trading entities. This would be far more effective, and significantly less complex, than trying to apply the law through contractual arrangements “along the transaction chain”.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

4 May 2022 · Sanctions

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Apr 2022 · CMU, Consolidated tape

Response to Review of the regulatory framework for investment firms and market operators (MiFID 2.1)

22 Mar 2022

ICMA is pleased to provide its feedback to the European Commission regarding its proposed MiFIR amendments, published 25 November 2021. See attached file for full details. Many thanks, Elizabeth B Callaghan ICMA
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Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur)

7 Mar 2022 · MiFIR Review

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

17 Nov 2021 · Conditions in the markets

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Oct 2021 · MiFIR

Meeting with Mairead McGuinness (Commissioner)

7 Jun 2021 · Record speech on Priorities of DG FISMA for the ICMA conference.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

22 Apr 2021 · Financial markets

Response to Central securities depositories – review of EU rules

1 Apr 2021

Introduction On behalf of its wide and diverse international membership (including asset managers and investors, banks and broker-dealers, as well as market infrastructures), the International Capital Market Association (ICMA) would like to take this opportunity to highlight the importance of including Settlement Discipline, in particular the provisions for mandatory buy-ins (MBI), in the Review of CSDR. ICMA’s members firmly believe that in its current form, the MBI framework is not fit for purpose and is in urgent need of substantive revision before attempting implementation. Furthermore, even if amended, the mandatory nature of the buy-in requirement is likely to have adverse impacts on bond market liquidity, functioning, and stability. Considerations In its recent response to the European Commission’s Targeted consultation on the CSDR Review (which is submitted with this feedback), ICMA argues that buy-ins, whether regulatory or contractual, should be discretionary and not mandatory. Mandating buy-ins will have adverse impacts for European bond market efficiency and liquidity. The response presents quantitative analysis to illustrate the scale of the costs that market participants (particularly investors) are likely to incur. ICMA also provides analysis using settlement efficiency data that illustrates not only how extensive and disruptive a mandatory buy-in regime would be for European bond markets under normal conditions, but that the procyclical impacts during the March-April 2020 COVID-19 market turmoil could have been extremely disruptive. If buy-ins are to remain part of CSDR, this will still require a number of essential revisions, including: (i) symmetrical payments for the buy-in and cash compensation differential; (ii) the introduction of a pass-on mechanism; (iii) greater flexibility in the requirement to appoint a buy-in agent; (iv) a clarification (and narrowing) of scope; (v) a more workable cash settlement (‘cash compensation’) mechanism for illiquid bonds; (vi) more tailored timelines for completing the buy-in; and (vii) guaranteed delivery for the buy-in process. It is difficult to see how the regime could be successfully implemented without these amendments. ICMA and its members therefore argue that is essential that Settlement Discipline, in particular MBIs, is a key focus of this Review and subsequent Refit. Timing ICMA would also like to take this opportunity to highlight the industry concerns recently raised in the cross-industry letter co-signed by 15 different associations representing a wide range of stakeholders in the European and global financial markets. The letter points out that the implementation of MBIs is a significant undertaking for the entire financial market, not only in Europe, but globally, involving not only extensive system developments, but also major client outreach across multiple markets and jurisdictions to undertake contractual papering and remediation. Implementing the mandatory buy-in requirements whilst the authorities concurrently review and revise the regulation will at best result in ongoing implementation efforts and investment being rendered redundant; while at worst it will mean repeating the exercise. The letter notes that creating such uncertainty around a regulatory implementation project of this profile and scale is damaging to the development and reputation of the EU’s financial markets. The associations suggest that a far more robust approach would be to make the required revisions to the CSDR mandatory buy-in regime before attempting implementation. Conclusion ICMA would therefore emphasize not only the importance of reviewing and revising the MBI provisions before attempting implementation, but also the urgency for providing clarification to market participants and stakeholders, in Europe and globally, that sufficient time will be provided to facilitate implementation once the revisions to the regulation are passed into law.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

12 Feb 2021 · Secondary bond markets, Benchmarks & Sustainability

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

The International Capital Market Association (ICMA) welcomes the opportunity to provide feedback on the draft Delegated Act (“The Draft Act”). ICMA is a membership association, headquartered in Switzerland, committed to serving the needs of its wide range of members. These include private and public sector issuers, financial intermediaries, asset managers and other investors, capital market infrastructure providers, central banks, law firms and others worldwide. ICMA currently has around 600 members located in over 60 countries. See: www.icmagroup.org. ICMA’s transparency register number is 0223480577-59. This feedback is given on behalf of ICMA and its constituencies primarily in this case from the GBP Executive Committee (GBP ExCom) with also the input of the Sustainable Finance Committee (SFC). In addition, we are pleased to inform you that the Association for Financial Markets in Europe (AFME) representing the voice of Europe’s wholesale financial markets has also endorsed the feedback we are providing. Please see our full response to the consultation in the pdf document attached on the European Commission’s portal.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

22 Sept 2020 · Sustainable finance; Central Securities Depositories Regulation

Response to Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

11 Sept 2020

ICMA’s Asset Management and Investors Council welcomes the opportunity to comment on the draft delegated act seeking to review research unbundling rules as part of the Commission's overall coronavirus recovery strategy. Unbundling has clearly not contributed to revive SME research (which was already on the decline prior the entry application of MiFID 2), but following the extensive restructuring undertaken by the industry in order to meet the new requirements, partially reviewing this provision will not tackle the issue to any meaningful extent. The majority of our members would practically not be able to make use of the options proposed and we outline the reasons why below. There may however be certain small specialist firms who are able to make use of this option. Following the introduction of MiFID 2 a majority of large asset managers have decided to absorb the cost of research on their P&L. This required significant operational change and extensive negotiations with research providers. It also required communications exercise with clients. These asset managers are very unlikely to ask investors to return to paying for research again. Regardless of their current set-up, making use of this optional regime comes with several other implementation difficulties for asset managers: •The proposal seems to ignore that mandates and funds very often invest across asset classes such as large caps, small caps, and fixed income. Implementing a dual regime within a fund/mandate would be onerous, not to say confusing for investors. It is very unlikely to be appealing, especially for large asset managers managing hundreds of funds and mandates. •This proposal might be complicated in practice for fixed income instruments, since structurally we cannot easily distinguish the share of the value attributed to research in the bid/ask price knowing that for fixed income there is no brokerage fee. •Monitoring companies to ensure that they remain under the EUR 1bn threshold with market volatility, and explaining this to clients, is operationally burdensome. •The proposal assumes that asset managers wish to trade with the same brokers from whom they will also buy research. •The term “exclusively” in Article 13 paragraph 10 could create another problem. If several types of research are provided together (e.g. through a “package” contract), should we then make two distinct contracts? Furthermore, we doubt that the new regime would contribute to revive SME research. Payment for research is often centrally budgeted within asset managers. The research is used across all types of funds. If exercised, the EC proposal would create an investment silo meaning that this cross-subsidy could not work. Given the operational challenges highlighted above, we believe it is critical to make sure that the regime remains optional and under the mutal agreement of both asset managers and research providers. Neither asset managers nor research providers should be required to re-bundle. Therefore, considering the concerns expressed above, we recommend the EC consider other policy options to support SME research and funding: •Free trial: AMIC members would welcome an amendment extending the trial period to 6 months to match the bond research cycle. Currently, ESMA has limited trial periods to three months. This approach clashes with the bi-annual research cycle and is not helping independent research firms, whose visibility with investors is ensured by sending research. In addition, several trial periods with a given sell-side research firm could also be allowed, but on different classes of financial instruments. •Issuer-sponsored research: Issuer-sponsored research is a useful tool for investors and issuers and could be further promoted by the EU. The EC could create a pan-European framework for issuer-sponsored research, which is currently tackled in various ways across EU jurisdictions.
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Response to Integration of sustainability risks and factors related to alternative investment fund managers

6 Jul 2020

The Asset Management and Investors Council of ICMA supports the integration of sustainability risks among other risks to be considered by fund managers (i.e. risk management policy) but is opposed to other amendments singling out sustainability risks in several general articles. We believe the references to these articles should be deleted, as singling out sustainability risks in such general articles could have implications regarding the weighing of other risks and potential unintended consequences. For instance, all risks need to be considered when assessing potential conflict of interests and not predominantly sustainability risks. Furthermore SFDR, which requires fund managers to inform clients how they assess sustainability risks, already implies significant changes from organisation, resources, and management and already covers due diligence requirements. Singling out sustainability risks in such broad articles is therefore not only inappropriate from a risk management perspective, it also seems unnecessary from a regulatory policy development perspective. From a proportionality perspective, we do not think it is necessary to expressly require specific resources to manage sustainability risks as firms may wish to consider different set ups, according to their size and core focus, including the possibility to delegate part of the performance of risk management or portfolio management activities. Until the revised NFRD becomes applicable (at the earliest 2023-2024) and progress is made on a common standard, the disclosure of sustainability risks on a qualitative basis only should be clearly allowed. There is indeed currently no standardized and audited data that fund managers could rely on to perform the quantitative assessment required under SFRD. Beyond the lack of data from issuers and uncertainty on ESG ratings, prudential supervisors themselves recognise the difficulty in assessing quantitatively sustainability risks. The EC could rely on the recital 15 of SFDR and the upcoming delegated acts on the integration of sustainability risks to clarify expectations. This needs to be done for all actors in the scope of SFDR.
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

6 Jul 2020

The Asset Management and Investors Council of ICMA supports the integration of sustainability risks among other risks to be considered by fund managers (i.e. risk management policy under article 38 of the Commission Directive 2010/43/EU) but is opposed to other amendments singling out sustainability risks in several general articles such as articles 4, 5, 9, 17 and 23). We believe the references to these articles should be deleted, as singling out sustainability risks in such general articles could have implications regarding the weighing of other risks and potential unintended consequences. For instance, all risks need to be considered when assessing potential conflict of interests and not predominantly sustainability risks. Furthermore SFDR, which requires fund managers to inform clients how they assess sustainability risks, already implies significant changes from organisation, resources, and management and already covers due diligence requirements. Singling out sustainability risks in such broad articles is therefore not only inappropriate from a risk management perspective, it also seems unnecessary from a regulatory policy development perspective. From a proportionality perspective, we do not think it is necessary to expressly require specific resources to manage sustainability risks as firms may wish to consider different set ups, according to their size and core focus, including the possibility to delegate part of the performance of risk management or portfolio management activities. Until the revised NFRD becomes applicable (at the earliest 2023-2024) and progress is made on a common standard, the disclosure of sustainability risks on a qualitative basis only should be clearly allowed. There is indeed currently no standardized and audited data that fund managers could rely on to perform the quantitative assessment required under SFRD. Beyond the lack of data from issuers and uncertainty on ESG ratings, prudential supervisors themselves recognise the difficulty in assessing quantitatively sustainability risks. The EC could rely on the recital 15 of SFDR and the upcoming delegated acts on the integration of sustainability risks to clarify expectations. This needs to be done for all actors in the scope of SFDR.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

In line with the points raised under the consultation on the integration of sustainability risks in UCITS, the Asset Management and Investors Council of ICMA would suggest to the EC to consider similar changes regarding the integration of sustainability risks in investment firms (MiFID). In addition, we urge the EC not to limit the scope of article 8 products via distribution rules (Recital 6 and article 1). The consideration of adverse impacts is not yet well defined and its implication for the product supply is not well understood. Furthermore, article 8 products under SFDR are not obliged to consider these factors but simply required to disclose whether and if so how it does consider it. We are concerned that the EC is proposing to crowd investors into sustainable products of which there are expected to an extremely limited number given the stringent requirements anticipated under the draft RTS (do no significant harm objective to be assessed against 50 indicators). The benefit of ESG products should not be dismissed: they are contributing to channel assets towards sustainable or neutral investments on a larger scale, while offering a great level of diversification and investor protection. We strongly believe that policymakers can and should allow a diversity of sustainable products, providing a range of different approaches to sustainable investment to suit an array of asset owner needs and motivations. Some flexibility is needed to allow for new products, which may achieve sustainability goals by different routes and meet different needs and preferences from investors (notably from a risk management perspective).
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

16 Jan 2020 · Capital Markets Union, Sustainable finance

Response to A simplified prospectus for companies and investors in Europe

21 Dec 2018

Please find attached the feedback of the International Capital Market Association (ICMA) on the draft delegated regulation and associated annexes supplementing the Prospectus Regulation as regards the format, content, scrutiny and approval of the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market. We would be happy to discuss this feedback. Yours sincerely Charlotte Bellamy Director - Primary Markets Charlotte.Bellamy@icmagroup.org +44 20 7213 0340
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Response to Draft Delegated Act amending the Commission Delegated Regulation on the Liquidity Coverage Ratio ('LCR')

21 Feb 2018

The ICMA appreciates the valuable contribution made by the European Commission through this public consultation process and would like to thank the European Commission for its careful consideration of the points made in the attached response and in the more detailed response of the AFME to which this ICMA response letter refers. In brief, the ICMA is supportive of the LCR, which represents an important and broadly successful element within the package of financial regulatory reforms enacted in response to the financial crisis. Nevertheless, refining this through a targeted amendment of the LCR Delegated Regulation can further improve the LCR. It also presents a valuable opportunity for integration into the LCR Delegated Regulation of the new simple, transparent and standardised (STS) criteria for securitisation, particularly including for the LCR treatment of asset-backed commercial paper (ABCP) - which is an important financing tool for the real economy.
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Response to Review of the European Supervisory Authorities

23 Jan 2018

The ICMA’s Asset Management and Investors Council (AMIC) was established in March 2008 to represent the buy-side members of the ICMA membership. ICMA is one of the few trade associations with a European focus having both buy-side and sell-side representation. Our investor members represented by the AMIC would like to take this opportunity to comment regarding the proposals by the European Commission to reform the European Supervisory Agencies (ESAs) and the European Systemic Risk Board (ESRB). AMIC members already contributed to the May 2017 ICMA response to the consultation by the European Commission. Many of our viewpoints in this document are based on the original work carried out by ICMA in responding to that earlier official consultation. This feedback also complements the work done by the ICMA primary market constituency in their response to the specific part of the proposal concerning prospectuses (links to these responses are available in our attached file). AMIC members would like to take the opportunity to welcome many of the very positive aspects of the proposals. ICMA and AMIC are strong supporters of Capital Markets Union (CMU) and we welcome proposals which will help to deliver better functioning capital markets for investors: • Supervisory convergence: It is helpful that the concept of a single supervisory handbook is extended from the EBA to ESMA and EIOPA. ESMA and EIOPA can play an important role in further promoting regulatory convergence on the same basis that EBA has done in banking. • ESG factors: As responsible investors we agree with the proposal to require the ESAs to consider ESG factors and to provide guidance on how firms can consider sustainability in their investment decisions. • Guidance and recommendations: We strongly support the requirement to carry out cost-benefit analyses for new guidance and recommendations. Guidance and recommendations play an increasingly important role in the single rulebook process in Europe. • Third country equivalence: It is helpful that the ESAs’ expertise can be harnessed to improve equivalence deliberations by the European Commission. • Collection of information: Investors strongly support greater centralisation of data in ESMA, which we will build on in our comments below. Nevertheless, AMIC members have some significant concerns with several elements of the text, which we believe will not serve the best interests of end-investors in Europe. These proposals should be revisited if this framework is to be successful in increasing supervisory convergence and addressing the challenge of the UK leaving the EU. Our significant concerns, which we lay out in greater detail in the attached file, are in the areas of: • Direct supervision of funds; • ESMA opinions on delegation arrangements; • Funding arrangements; • Consultations on Q&As; and • Organisation of the ESRB. In conclusion, the AMIC recognises the significance of these reforms. There are already many welcome elements in the proposals, but, as we have elaborated, we also consider that there is scope to significantly improve the overall package. We hope the Commission will take our views into account and would be pleased to discuss them at your convenience.
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Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

22 Nov 2017 · Mifid II, corporate bond

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

30 Nov 2016 · Primary market regulation, Secondary market liquidity, Investor involvement,The Commission’s review of the EU macro-prudential policy framework

Meeting with Jonathan Hill (Commissioner)

26 Jan 2015 · Capital Markets Union