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London Stock Exchange Group

LSEG

London Stock Exchange Group is a leading global financial markets infrastructure and data provider.

Lobbying Activity

London Stock Exchange Group urges comprehensive digital regulatory simplification

14 Oct 2025
Topic — EU initiative to simplify digital regulations including data, AI, and cybersecurity rules.
Message — The organization requests harmonized data frameworks, streamlined cybersecurity reporting, clearer AI Act guidance, and resolution of tensions between GDPR and AML rules. They seek a unified approach to replace fragmented regulations and reduce compliance burdens.123
Why — This would reduce compliance costs and operational burdens for their cross-border operations.45
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LSEG urges better capital treatment for direct CCP repo exposures

5 Sept 2025
Topic — This consultation supplements technical rules for the European insurance and reinsurance sector.
Message — LSEG requests guidance on granting preferential capital treatment for direct CCP repo exposures. They advocate for aligning repo risk measurement techniques with those used for derivatives to encourage clearing.12
Why — The proposal would incentivize insurers to use LSEG's clearing services for their liquidity needs.34
Impact — Banks currently acting as intermediaries may see reduced demand for their private lending services.56
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Meeting with Jennifer Robertson (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

3 Jun 2025 · Clearing, SIU

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

3 Jun 2025 · Clearing of government bond repo transactions

Meeting with Martin Merlin (Director Financial Stability, Financial Services and Capital Markets Union)

15 May 2025 · Introductory meeting with new CEO

Meeting with Alessandra Sgobbi (Head of Unit Climate Action)

10 Apr 2025 · Exchange of views on sustainable finance

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

31 Mar 2025 · Exchange of view on the omnibus and sustainable finance more broadly

LSEG Urges EU to Unify Supervision and Simplify Green Rules

31 Jan 2025
Topic — The consultation seeks input on removing regulatory barriers within the European single market.
Message — LSEG requests unified supervision for clearing houses and faster approval for risk models. They also want sustainability rules simplified and global reporting standards aligned.123
Why — Reducing regulatory delays would allow the group to launch financial products significantly faster.45
Impact — Local cloud providers lose protectionist advantages if rules requiring EU-based technology are removed.6
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Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and NASDAQ and

24 Jan 2025 · MiFIR Review

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

23 Jan 2025 · Omnibus

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

23 Jan 2025 · Omnibus

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and FTI Consulting Belgium and

21 Jan 2025 · Benchmark Regulation

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

16 Oct 2024 · Benchmarks Regulation

Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

7 Dec 2023 · Benchmark Regulation

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur) and FIA European Principal Traders Association, part of FIA, Inc.

13 Oct 2023 · European Market Infrastructure Regulation (EMIR) Review (Meeting with APA)

LSEG Urges Proportionality and Clearer Definitions in ESG Rules

1 Sept 2023
Topic — A consultation on improving the transparency and reliability of ESG ratings in financial markets.
Message — LSEG requests clearer definitions for ESG scores and ratings to ensure legal certainty. They advocate for a proportionate regulatory framework aligned with international standards to support innovation. Finally, they propose extending the implementation timeline to eighteen months.123
Why — These changes would protect LSEG’s automated scoring models and reduce potential compliance costs.45
Impact — End users would suffer from higher costs and reduced market competition under stricter rules.67
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Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur)

28 Jun 2023 · EMIR

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

22 Jun 2023 · EMIR III, clearing ecosystem

Meeting with Aurore Lalucq (Member of the European Parliament, Shadow rapporteur)

11 Apr 2023 · EMIR

LSEG urges EU to simplify third-country benchmark regulations

29 Mar 2023
Topic — This consultation reviews EU rules for financial benchmarks and their international usage.
Message — LSEG recommends limiting the regulation's scope to critical benchmarks that are systemically important. They advocate for an improved recognition route to replace the complex endorsement option.123
Why — Simplifying the regime would reduce significant recurring costs and administrative burdens for LSEG.45
Impact — Regulators lose oversight over benchmarks that no longer fall under the narrowed scope.6
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Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

9 Feb 2023 · Digital trade and data

Meeting with Lesia Radelicki (Cabinet of Commissioner Helena Dalli)

2 Feb 2023 · Exchange views on the implementation of the Strategy, including the recently agreed Pay Transparency directive and the Gender Balance on Board directive, and share LSEG’s corporate experience in managing, and mitigating, gender inequalities as well

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

9 Dec 2022 · CCPs, MiFIR

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Nov 2022 · sustainable finance

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

7 Jul 2022 · DTO CCPs

Meeting with Valeria Miceli (Cabinet of President Ursula von der Leyen)

7 Jul 2022 · Clearing business in the EU: competitiveness of EU CCPs, DTO equivalence, EU supervision.

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

1 Jul 2022 · Central clearing

Meeting with Danuta Maria Hübner (Member of the European Parliament)

30 Jun 2022 · EMIR

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Euronext and

26 Apr 2022 · EU Clearing Strategy CCPs

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

24 Feb 2022 · consolidated tape sustainable finance clearing CCPs

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

2 Dec 2021 · UK CCP

Response to Revision of EU rules on Anti-Money Laundering (recast)

18 Nov 2021

Please find attached LSEG's comments on the EU Package on Preventing Money Laundering and Terrorist Financing.
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Response to Revision of EU rules on Anti-Money Laundering (new instrument)

18 Nov 2021

Please find attached LSEG's comments on the EU Package on Preventing Money Laundering and Terrorist Financing.
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Meeting with Mairead McGuinness (Commissioner) and

9 Sept 2021 · Sustainable Finance & Market Infrastructure

Meeting with Mikuláš Peksa (Member of the European Parliament, Rapporteur)

4 Mar 2021 · Digital Operational Resilience Act

Meeting with Mairead McGuinness (Commissioner)

21 Jan 2021 · Introductory Meeting, Brexit, Sustainable Finance, Digital Resilience

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

14 Dec 2020 · MiFID II / Derivative Trading Obligation (DTO)

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

1 Apr 2020 · COVID-19 situation and the impact on financial markets

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

29 Jan 2020 · Mifid Review, Capital Markets Union

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis) and NASDAQ and

22 Oct 2019 · MIFID II

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

4 Apr 2019 · Brexit.

Meeting with Valdis Dombrovskis (Vice-President) and

4 Apr 2019 · Brexit, CMU

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

5 Feb 2019 · Brexit, EMIR

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

24 Jan 2019 · General financial stability and financial services issues

Meeting with Valdis Dombrovskis (Vice-President) and

16 Oct 2018 · Brexit

Response to Institutional investors' and asset managers' duties regarding sustainability

22 Aug 2018

· We support the Commission’s view that sustainability and the transition to a low carbon economy is key to ensuring the long term competitiveness of the EU economy. · LSEG is a thought leader in sustainable finance working closely with issuers and investors as a market infrastructure provider. · FTSE Russell is an FCA-authorised benchmark administrator and has been providing sustainability indexes and benchmarks since 2001, when it launched its pioneering index family FTSE4Good. It currently calculates over 100 sustainability indexes and assesses more than 4,000 listed companies globally against its ESG methodology, and over 14,000 companies against its Green Revenue taxonomy and data model. · We support transparency and disclosure, and already extensively publish factsheets and ground rules, as well as BMR compliant benchmark statements and methodology documents for all our benchmarks. Additional requirements for sustainability benchmarks should be proportionate, and best designed to help investors. · The transition to a low carbon economy represents a wide range of investment risks and opportunities for investors and there is not a single “best” approach on how to address this. We advise that ‘harmonising’ or mandating a specific methodology for low-carbon and positive carbon indexes may prove counter-productive. This is an area that is evolving very rapidly. There is no single best way of incorporating climate change considerations into the design of benchmarks, and innovation here should be encouraged. · For example, if you look at the evolution of these indexes, typically a number of years ago they were focused on Scope 1 and 2 carbon emissions. There has since been a focus on bringing fossil fuel reserves and the carbon intensity of those into the design of benchmark indexes. More recently FTSE Russell has been championing capturing the positives of the ‘green economy’ in those indexes. · We also have to be careful regarding false precision regarding indexes as a tool to achieve the important 2 degree objectives of the Paris Climate Agreement. Benchmarks generally reflect listed securities, so can contribute but not drive this important transition. · We recommend that the Commission’s proposals should support continuous evolution and enhancements in the methodologies of measuring climate risk and opportunity and incorporating this into benchmark index design. Further, we would suggest that the proposed new categories are optional standards for industry.
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Response to EU small listed companies Act

25 Jul 2018

• LSEG is delighted to respond to the European Commission’s proposed amendments to MAR and the Prospectus Regulation on the promotion of using SME Growth Markets (SME GM). We believe that SMEs will be willing to meet higher standards of regulation if the benefits warrant the investment and we therefore caution against any dilution of standards. Ensuring that the SME GM regime becomes a truly valued designation will not be achieved through changes to the regulatory framework alone and will require the stimulation of the wider SME ecosystem. • In general we welcome the various recalibrations that have been introduced in this proposal and we make a target set of suggestions for enhancing these so that sufficient optionality and flexibility is maintained in the SME Growth Market framework (e.g. on liquidity provision contracts) whilst preserving investor protection. We restate our support for the proposed new debt SME Growth Market definition which forms part of the separate but linked Commission Delegated Regulation and reiterate our warning about the risks of introducing a mandatory free float requirement, supported by quantitative data which demonstrates that requiring a minimum free float does not guarantee higher liquidity. Finally we assert that the Commission should be more ambitious and propose more fundamental and transformative measures to achieve their objective of promoting the use of SME Growth Markets (e.g. MiFID Investment Research and Prospectus Regulation thresholds). There are three sections to the attached paper. Part 1 deals with the MAR / Prospectus proposals; Part 2 reiterates evidence supporting our warning on the risks of a mandatory free float requirement; Part 3 recommends more transformative measures the Commission should adopt.
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Response to EU small listed companies Act

21 Jun 2018

LSEG welcome that a new, complementary definition of SME Growth Markets is to be introduced to allow debt markets also to qualify for the label where appropriate. This will support a greater adoption of the SME Growth Market framework and we are delighted that this should make it feasible in particular for our ExtraMOT Pro market to consider the potential benefits of applying for SME Growth Market status. We note the additional provisions intended to support increased volume and higher liquidity of shares traded on SME Growth Markets through minimum ‘free float’ requirements. However, we recommend to remove this stipulation in order to avoid unintended adverse consequences, reflecting the majority of stakeholder feedback to the commission’s consultation which broadly opposed introducing a minimum free float. The results of a separate consultation closed by the Exchange in December 2017 also overwhelmingly concluded that a qualitative approach to free float is appropriate and it remains of fundamental importance that a growth market is differentiated from Regulated Markets and is not hampered by numeric constraints which may result in potentially arbitrary outcomes for smaller companies. Finally, we support the proposal to allow debt-only issuers on SME Growth Markets not to require half yearly financial reports.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

Article 8, Paragraph 2 We seek confirmation of our interpretation that this is not intended to impact upon the current practice for UK Rights Issues and Open Offers where the event record date usually precedes the event announcement date. We believe that the market claims process for the above events in operation in the UK satisfies the minimum requirements set out in paragraph 2a.
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

24 Apr 2018 · Sustainable Finance, Benchmarks, Fiduciary Duties

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

19 Apr 2018 · Sustainable benchmarks

Response to Review of the appropriate prudential treatment for investment firms

8 Mar 2018

• LSEG welcomes the European Commission’s (the Commission’s) proposal for a Prudential Framework for Investment Firms. We recommend that the Regulation and Directive should be more proportionate than envisaged by the EBA in its application to principal traders acting as market liquidity providers, in order to support the Commission’s objectives for Capital Markets Union. The co-decision process represents a unique window to act because the EBA have declined to acknowledge the need to calibrate their advice to be consistent with the Commission’s CMU objectives (i.e. to support diversification away from an overreliance on bank financing in Europe). • LSEG welcomes and supports many elements of the Commission’s proposal. The overall objective to be more proportionate and acknowledge the lower risks posed by different types of institutions is laudable and in particular, we welcome that the framework is simpler, more coherent and consistent than the existing Capital Requirements Regulation with far fewer categories (Class 1 are systemic and subject to CRR; Class 2 are large but non systemic and Class 3 are small non systemic – with more proportionate regimes). LSEG customers operating in the asset management sector have told us that they welcome that the framework is more consistent with the UCITS and AIFMD environment. Finally, we broadly support the governance and remuneration aspects, and in particular, that there is no extension of the CRR bonus cap also to cover investment firms because this is a proportionate reflection of the different risk incentives of banks and investment firms. • We recommend that the framework be enhanced with a simple fix in order that it can more easily pass the ‘CMU test’ and deliver on the vision of CMU as consistently articulated by the leadership of the Commission at the highest levels. The briefing attached is split into three sections. First, it explains the important role played by principal traders acting as market liquidity providers; second, it reveals, based on the EBA’s advice, the adverse impact that the Commission’s framework would have on CMU if applied to the legislative framework without amendment; finally, it provides a simple amendment to enhance the regime in order to help it deliver on the Commission’s objectives for CMU.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis), Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

27 Feb 2018 · Capital Markets Union

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

21 Feb 2018 · CMU and affiliated initiatives including SME Growth market and prudential rules for investment firms - FinTech and Sustainable finance - ESA Review - Euribor

Response to Review of the European Supervisory Authorities

29 Jan 2018

LSEG supports the objectives of the European Commission to ensure a level playing field across the Single Market through its proposal on the review of the European Supervisory Authorities. Please find our full response attached. We agree with the principle of supervisory convergence in order to reduce any real or perceived regulatory arbitrage between jurisdictions. At the same time we agree with the Council that some recalibrations of the proposal are needed to ensure an effective balance of powers and governance oversight for ESMA, with a more incremental approach towards building a single capital markets supervisor. We believe that any increase in ESA powers should be complemented by appropriately enhanced accountability and a correctly calibrated framework of decision making drivers including objectives that support international competitiveness and growth as well as financial stability. In particular we propose five key enhancements which a transformed ‘new ESMA’ must possess in order to support its important mission and set out three policy tests to determine which direct supervisory powers should be granted to ESMA. We also suggest a new model of direct extraterritorial licensing for ESMA to supervise third country financial institutions with direct application of the acquis, underpinned by regulatory co-operation but without duplicative equivalence assessments. We call on the Commission to raise the profile of the ESA review with market participants and encourage them to engage with the process. Industry players are focused on MiFID II/R implementation and need to understand the significance of the ESA review and its interconnectedness with multiple other critical regulatory proposals (e.g. EMIR 2.2). The co-legislators should assess the impact of the ESA review against the full context of relevant dossiers (e.g. EMIR 2.2; ECB Article 22; CCP R&R). An appropriate balance of powers between all relevant regulatory organisations should be established with the complete picture in mind. In addition a clear vision for ESMA’s role must be defined, particularly in respect of its direct supervision of CCPs and the interplay between the ESMA Executive Board and the CCP Executive Session. In our view the balance between different aspects of ESMA comprises: 1) Standard Setting; 2) ESMA’s practices as a supervisory body for EU institutions; and 3) as licensor of third country financial institutions. Transformational enhancement is needed for ESMA if it is to deliver its objectives effectively with a significantly increased mandate and powers. ‘New ESMA’ must be a fundamentally enhanced organisation if it is to be able to effectively play a greater role in supervision. Significant investment in technology and experienced staff would need to be made, which would take considerable time. In addition, an enhanced ESMA would demonstrate enhanced transparency, with appropriately calibrated decision-making oversight to complement an increase in powers. We support an enhanced role for ESMA and to make it work effectively the following features are needed: 1. Accessibility. ESMA should be provided with the necessary resources to enable it to maintain close and continuous contact with their supervised entities. 2. Empowerment. ESMA cannot have its ability to act unduly hampered by other regulatory players (e.g. Central Banks of Issue) otherwise it cannot deliver its objectives appropriately. 3. Accountability. ESMA deserves an enhanced oversight structure in order to ensure even greater transparency with market participants (e.g.in designing the Executive Board) 4. Proportionality. Building on ESMA’s targeted approach. 5. International Competitiveness. ESMA should be empowered with an objective to support the international competitiveness of Capital Markets Union in order to ensure that Europe is well positioned to take full advantage of global growth opportunities.
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Response to 2nd Data Package

23 Jan 2018

London Stock Exchange Group (LSEG) is delighted to have the opportunity to provide feedback on the European Commission’s proposal for a regulation on a framework for the free flow of non-personal data in the EU. We welcome the European Commission’s effort to remove barriers for free flow of non-personal data by removing data localisation rules. We believe it is a significant step forward to establish a Digital Single Market and to increase EU’s economic competitiveness in an increasingly digitalised society across the globe. Furthermore, the data economy being global, the removal of barriers could bring significant international economic opportunities for the EU. We believe that a global collaborative approach is crucial to materialise the great potential free flow of data could have and to enhance EU’s competitiveness. LSEG supports the European Commission’s proposal to limit the only justifiable data localisation requirement cases to be on the grounds of public security, as laid out in Article 4 of the proposal. Furthermore, we welcome the proposed review of existing requirements, notification of remaining or new requirements to the Commission and transparency measures. However, we encourage clarification on the definition of public security to avoid potential interpretation issues when in adoption that leads to fragmentation of rules across member states and thus not allowing stakeholders to fully benefit from the proposal. In terms of the scope, we are encouraged to see that the proposal applies to data in both cases where it is provided as a service to users residing or having an establishment in the Union, regardless of whether the provider is established or not in the Union, or, carried out by a natural or legal person residing or having an establishment in the Union for its own needs. We believe the proposal ensures consistency and thus a level playing field for service providers regardless of their geographic location. We welcome the proposed approach to address data portability, in for instance, the context of cloud. We believe the establishment of industry-led codes of conduct detailing the information on data porting conditions would lower service users’ lock in risks and reduce the counterparty risk exposure in the case of bankruptcy of a cloud service provider. Currently, we have observed that it is often a matter of bilateral negotiations with cloud providers. We believe that the proposal would lead to standardisation of services and act as a catalyst to enable users to reap all of the potential benefits it could realise with adopting this new technology by introducing a more competitive environment among cloud providers that promotes choices, innovation and efficiency.
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Response to Commission Delegated Act on fees under Article 11(2) SFTR

14 Dec 2017

London Stock Exchange Group (LSEG) and UnaVista appreciate the opportunity to comment on the European Commission’s draft delegated regulation under article 11(2) of the Securities Financing Transaction Regulation (SFTR) specifying the fees the European Markets Authority (ESMA) charges trade repositories (TR) for their supervision. LSEG is a diversified global market infrastructure and capital markets business, at the heart of the world's financial community. LSEG operates a broad range of international equity, bond and derivatives markets, post trade and risk management services, is a global leader in index and analytic solutions and a developer of platforms and capital markets software. LSEG operates UnaVista (UV), a rules-based data matching and validation service, available globally and designed to manage multiple workflows irrespective of market, geography and asset class. UnaVista is an Approved Reporting Mechanism (ARM) under the MiFID regime and UnaVista Ltd is an authorised and regulated EMIR Trade Repository (TR) operating across all asset classes for both exchange traded derivatives and OTC derivatives. This response builds upon LSEG’s response to ESMA’s technical advice to the Commission on fees for TRs under SFTR and on certain amendments of for fees under EMIR (ESMA/2016/1672) in Feb 2017. UV TR welcomes the regulatory authorities’ initiative to harmonise the TRs fees regime under both EMIR and SFTR frameworks. While the Art. 11 of SFTR explicitly states that ESMA shall charge TRs fees that are proportionate to the turnover of the TR, only; the Art. 3 of the EMIR TR Fees Regulation [Commission Delegated Regulation (EU) No 1003/2013] states that the Fees shall be the sum of one third of each of the following: a) the revenues generated from the core functions of centrally collecting and maintaining records of derivatives of the trade repository on the basis of the audited accounts of the previous year (n-1), divided by the total revenues generated from the core functions of centrally collecting and maintaining records of derivatives of all registered trade repositories during the previous year (n-1); b) the number of trades [Unique Trade Identifiers] reported to the trade repository during the previous year (n-1), divided by the total number of trades reported to all registered trade repositories during the previous year (n-1); c) the number of recorded outstanding trades on 31 December of the previous year (n-1), divided by the total number of recorded outstanding trades on 31 December of the previous year (n-1) in all registered trade repositories. On the occasion of commenting the proposed SFTR TR Fees act, it would also be beneficial to understand as of when the EMIR registered TRs will commence conforming with the harmonised guidance proposed in ESMA’s technical advice report regarding supervisory fees for TRs under SFTR and on certain amendments to Fees to TRs under EMIR on 21st April 2017. Managing deficits and surpluses under EMIR and SFTR ESMA’s current standard practice is to charge all TRs a global amount of fees (increased on an yearly basis) as approved by their Management Board at the end of each calendar year. It is set up as result of ESMA’s budgeting allocation of the overheads expenditure. In our TR experience, ESMA has made use of a deficit/surplus calibration exercise. The new initiative of non-recovery of surpluses/deficits set up in the proposed act does not seem to set a level playing field: Recital (7): “Should deficits occur, ESMA should not recover the deficit from the trade repositories. Should the deficit be significant, ESMA should analyse the reasons and amend its pro-forma supervisory costs for the next budgeting period. With regard to surpluses, surpluses of fees should not be recovered by trade repositories”. We would welcome a more flexible approach in terms of substantial surpluses of fees to be analysed by ESMA and be recovered by trade repositories.
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Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

6 Dec 2017

London Stock Exchange Group (LSEG) is delighted to have the opportunity to provide feedback on the European Commission’s proposal for a regulation on ENISA and on ICT cybersecurity certification. As one of the largest operators of safe, efficient and diversified international financial market infrastructures (FMIs), LSEG has been undertaking prudent risk management across all operational risk areas including cyber resiliency. We recognise that cyber resilience can be a determining factor in the overall resilience of the financial system and broader economy. Due to the interconnectedness of FMIs, cyber attacks in the financial sector have the potential to create widespread financial instability. For this reason, we fully support the policymakers and the industry's ongoing efforts to enhance cyber resiliency and help raise the bar for the whole financial industry and wider economy. LSEG welcomes the proposal for ENISA to provide a single point of expertise. We encourage ENISA to coordinate at a pan-EU level and collaborate on a global level to achieve harmonisation. We consider that the consistency and consideration of existing requirements would be key for regulatory compliance. In our view, it is crucial to ensure that an internationally consistent approach is taken in order to mitigate against any regulatory arbitrage and to raise the bar on a global level across industries. A globally harmonised approach would allow companies with global reach to operate across borders with predictability and clarity of standards. It would ensure efficient use of time and resources within the businesses. We are encouraged to see that the Commission includes third country/international organisation cooperation in the proposal and welcome more clarity on the mechanism of how this will be achieved. We welcome the proposal for ENISA to produce EU Cybersecurity Technical Situation Report as part of the regular cooperation at technical level to support EU situational awareness. We also support the proposal to have such report to be made publicly available after desensitised. With regard to information sharing, we believe that collective effort is essential to achieve greater cyber resilience globally. However, we would like to seek further clarification on the channels/sources for such information gathering exercises, whether they would utilise existing information at member state level or request additional feeds of information. Considering the existing arrangement of information submission to NCAs, additional and excessive information submission will increase the burden on institutions at an operational level. While we welcome the initiative to have an annual cybersecurity exercise at Union level, as laid out in Article 6 of the proposal, we would like to note that our various regulated entities already participate in exercises with NCAs and institutions such as the Bank of England and FS-ISAC. Whilst we believe it is important for such exercises to be carried out, it can be time consuming and resource intensive. With these considerations in mind, we would recommend alignment to and harmonisation with existing exercises. LSEG supports the proposal to establish a pan-EU cybersecurity certification scheme. However, we encourage further clarification on the scope of the “ICT products and services” that it aims to cover. Consistent with the suggestion above, we would again welcome harmonisation between the to-be-established cybersecurity certification scheme and existing certification regimes at member state and international level. We would also support, if such certification is to be established, its use by institutions as a stamp of confidence for regulators to enable them to substitute similar cybersecurity exercises/requirements needed at EU level to avoid excessive and multiple cybersecurity regulatory schemes.
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Response to Further amendments to the European Market Infrastructure Regulation (EMIR)

30 Oct 2017

LSEG welcomes the opportunity to respond to the European Commission legislative proposal amending EMIR relating to the supervision of EU and third-country CCPs, leveraging from its experience supporting the operations of the CCPs of the Group in Italy, France and the UK. Please see the feedback provided in the attached comment letter.
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Response to Technical elements of the definitions set out in the Benchmark Regulation

20 Jul 2017

London Stock Exchange Group (“LSEG”) and FTSE Russell support the work on the Level 2 of the Benchmarks Regulation (“BMR”), a key piece of legislation which will ensure the integrity and robustness of benchmarks. We welcome the four European Commission delegated acts published in June. We would like to bring the following elements to the European Commission’s attention: 1. Commission delegated act specifying technical elements of the definitions laid down in paragraph 1 of Article 3 of the Regulation. Making available to the public. We fully support the European Commission in its effort to define a “determined number of recipients” of a figure. We believe that regardless the number of recipients, it is the possibility to access or restrict the access to the figure, which is crucial. ESMA recognised, but did not offer a limitation for the cases where an administrator has provided the figure to its client to use that figure for its own purposes pursuant to a binding contract (regardless of the number of employees of the client). Further, we suggest it would be helpful to clarify that “connected to” the index provider can mean a party to a contract with the index provider. To capture such situation, we suggest the following amendment: “(…) where the figure is made accessible to a potentially indeterminate number of legal and natural persons other than the index provider or the user of the figure or other than a determined number of recipients contractually bound to or otherwise connected or related to the index provider. 2. Commission delegated act specifying how the nominal amount of financial instruments other than derivatives, the notional amount of derivatives and the net asset value of investment funds are to be assessed We appreciate that the European Commission has also adopted a pragmatic view and points the administrators to the regulatory data for both the nominal amount of financial instruments other than derivatives and the notional amount of derivatives. As the data is currently not available and will not be available on the date the BMR applies, we welcome the possibility to assess the benchmarks on the “best effort” and “best ability” basis. 3. Commission delegated act on the establishment of the conditions to assess the impact resulting from the cessation of or change to existing benchmarks We have no comments on the specific criteria, but would suggest clarifying that they do not apply in a cumulative manner – i.e. not all of the criteria listed have to be satisfied in order to fulfil the conditions. 4. Commission delegated act specifying how the criteria of Article 20(1)(c)(iii) are to be applied for assessing whether certain events would result in significant and adverse impacts on market integrity, financial stability, consumers, the real economy or the financing of households and businesses in one or more Member States We have no comments. * * * * * * * * * About FTSE Russell, a part of London Stock Exchange Group (LSEG). FTSE Russell is a global index leader that provides innovative benchmarking, analytics and data solutions for investors worldwide. FTSE Russell calculates thousands of indexes that measure and benchmark markets and asset classes in more than 80 countries, covering 98% of the investable market globally. FTSE Russell index expertise and products are used extensively by institutional and retail investors globally. Approximately $12.5 trillion is currently benchmarked to the FTSE Russell indexes. For over 30 years, leading asset owners, asset managers, ETF providers and investment banks use FTSE Russell indexes to benchmark their investment performance and create ETFs, structured products and index-based derivatives.
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Response to EMIR Amendment

18 Jul 2017

The London Stock Exchange Group (“LSEG”) welcomes the opportunity to respond to the European Commission legislative proposal amending EMIR. Please see the feedback provided in the attached comment letter.
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Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

29 Jun 2017 · EMIR review

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

31 May 2017 · CMU; EMIR review

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen), Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

17 Jan 2017 · Presentation of the publication "1000 companies to inspire Europe"

Meeting with Markus Schulte (Digital Economy) and Deutsche Börse AG and Freshfields LLP

30 Nov 2016 · Digitisation of financial services and capital union

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici), Simon O'Connor (Cabinet of Commissioner Pierre Moscovici)

15 Nov 2016 · EU location policy after the UK referendum, COM's in-depth investigation into the LSE/Deutsche Börse merger

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

8 Nov 2016 · CMU and other related issues

Meeting with Daniel Calleja Crespo (Director-General Environment)

18 Oct 2016 · Green Finance

Meeting with Valdis Dombrovskis (Vice-President) and

28 Sept 2016 · Financial services regulation including CMU, and proposed merger of DB and LSE

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

12 Aug 2016 · CCP Recovery and Resolution

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

11 Jul 2016 · Financial issues

Meeting with Chantal Hughes (Cabinet of Commissioner Jonathan Hill)

15 Jun 2016 · Regulation of CCPs

Meeting with Martin Selmayr (Cabinet of President Jean-Claude Juncker) and Deutsche Börse AG

2 May 2016 · Capital Markets Union; New Settlement for the United Kingdom

Meeting with Jonathan Hill (Commissioner)

18 Apr 2016 · Merge LSE/Deutsche Borse

Meeting with Astrid Cousin (Cabinet of Commissioner Margrethe Vestager)

13 Jan 2016 · Capital Market and presentation of the ELITE programme for SMEs

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

12 Oct 2015 · Markets in Financial Instruments Directive II/Prospectus Directive

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

12 Oct 2015 · Capital Markets Union

Meeting with Jonathan Hill (Commissioner), Jonathan Hill (Commissioner)

10 Jul 2015 · Financial Services Policy

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Commissioner Jonathan Hill)

11 May 2015 · Capital Markets Union

Meeting with Jonathan Hill (Commissioner)

23 Jan 2015 · Financial Services Policy

Meeting with Ioana Diaconescu (Cabinet of Commissioner Pierre Moscovici)

3 Dec 2014 · SME programme- Elite Europe and general economic outlook

Meeting with Jonathan Hill (Commissioner)

2 Dec 2014 · Financial Services Policy

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

2 Dec 2014 · Jobs, Growth, Stability and Capital Markets Union - Recovery and Resolution of CCPS