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Optiver

Optiver is a global market maker founded in Amsterdam, with offices in London, Chicago, Austin, New York, Sydney, Shanghai, Hong Kong, Singapore, Taipei and Mumbai. Established in 1986, today we are a leading liquidity provider, with more than 2,000 employees in offices around the world, united in our commitment to improve the market through competitive pricing, execution and risk management. By providing liquidity on multiple exchanges across the world in various financial instruments we participate in the safeguarding of healthy and efficient markets. We provide liquidity to financial markets using our own capital, at our own risk, trading a wide range of products: listed derivatives, cash equities, ETFs, bonds and foreign currencies.

Lobbying Activity

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

21 Jan 2026 · Prudential regime for investment firms (IFR/D)

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

14 Nov 2025 · Simplification

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

15 Oct 2025 · EU financial policy

Meeting with Dirk Gotink (Member of the European Parliament) and ABN AMRO Clearing Bank N.V. and Cboe Clear Europe N.V.

27 Jun 2025 · Capital markets

Meeting with Ugo Bassi (Director Financial Stability, Financial Services and Capital Markets Union)

5 May 2025 · Prudential regime for investment firms

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

10 Apr 2025 · Short meeting at the margins of the Eurofi High-Level Seminar in Warsaw

Meeting with Auke Zijlstra (Member of the European Parliament)

20 Mar 2025 · European Capital Markets and SIU

Response to Savings and Investments Union

7 Mar 2025

See attachment where we highlight a number of areas that policymakers should focus on. This is about 4 key pillars: 1. Converting savings into investments and building the capacity of capital for EU companies. 2. Making capital markets more accessible to new companies, including early-stage ventures such as start-ups and scale-ups. 3. Improving competitiveness within Europe by fostering greater market integration, efficiency and competition in capital markets. 4. Enhancing supervisory arrangements and regulatory simplification. This also includes closely examining where there might be self-imposed regulatory barriers such as the IFR/IFD regime that significantly inhibit the ability of European trading firms to support liquidity in European capital markets and compete globally at the same time.
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Meeting with Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

19 Feb 2025 · Exchange with Optiver on Regulation (EU) 2019/2033 (IFR)

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

27 Nov 2024 · Single and capital market integration

Meeting with Aura Salla (Member of the European Parliament)

26 Sept 2024 · Introductory meeting, EUs competitiveness

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament) and Bank of America Corporation and

11 Sept 2024 · Capital Markets Union

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

22 Feb 2024 · next decade’s challenges and opportunities for EU financial markets : functioning of the market structure, digitalisation of capital markets

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

30 Jan 2024 · IFR-IFD, Europe’s capital markets

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

17 Jan 2024 · Upcoming event on CMU

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

6 Oct 2023 · CMU

Meeting with Mairead McGuinness (Commissioner) and

21 Sept 2022 · Energy Derivatives market

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

17 Mar 2022 · Investment firms classification & commodities

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

1 Mar 2022 · MiFIR Review

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

8 Oct 2021 · CMU

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

22 Mar 2021 · CMU/MifID/Inv Firms Regime

Response to Commission Delegated Regulation amending the MiFID 2 Delegated Regulation with respect to systematic internaliser defint

12 Jul 2017

We thank the European Commission for the opportunity to provide feedback on the Commission's draft proposal. We are encouraged by the fact that the Commission sees the need to address the concerns from different stakeholders on the new SI regime. But we feel the changes as proposed by the Commission in the draft Delegated Regulation do not sufficiently address the real problem and will likely fail to prevent order flow from leaving the transparent order books of exchanges to the benefit of a large number of new systematic internalisers (SIs). We have received indications that a large volume of liquid equities is likely to move towards SIs. The caps on dark trading combined with the way the SI regime is currently designed, makes SIs simply too attractive to participants and likely to attract a disproportionate amount of the flow that was intended to move on-exchange. And we even see the SI regime also drawing in a number of new participants who do not currently participate in BCNs. This move of flow away from transparent, public exchanges has many unintended consequences for price discovery, liquidity distribution, transparency and market integrity. We believe there is one very important reason why the SI regime attracts so many new entrants and that is the fact they are not subject to the tick size regime, allowing SI to offer (usually meaningless) price improvement that is not attainable on public markets. If SIs are treated as a venue for the purpose of meeting the share trading obligation, it is difficult to justify why SIs are not subject to the same obligations when it comes to the tick size regime. But MiFID2/R allows SIs to easily price improve as compared to public markets by potentially infinitesimal amounts (e.g. a price improvement of 1/100 of a cent) – and transact inside the best bid/offer. This meaningless price improvement will however make SIs the de-facto destination of choice for Smart Order Routers (SORs) seeking best execution, but in the long term, at great cost for the public markets’ role in central price formation. So SIs will be able to free-ride off trading venues by using public quotes as their reference prices, while contributing nothing to price discovery. But if SI trading grows to the extent that some predict, implicit transaction costs will by definition rise as internalization harms the quality of the public markets on which it relies. To make things worse, SIs will be able to pick over order flow and send only the most unattractive (or “toxic”) order flow to the public market, making these public markets even less attractive. As a result of all this spreads are likely to widen overall (including on the SIs that rely on public prices as reference). The less volume that transacts on-exchange and the more toxic the order flow, the greater the risk intermediaries such as market makers will face in transacting there. They will have to compensate for this risk by widening spreads and lowering quoted size. In fact, the success of the SI regime may even undermine the market making obligations in MiFID 2 by scaring off participants willing to quote. To address this risk, we suggest the European Commission clarifies that tick sizes on SIs should be in compliance with the tick size regime established by MiFID2/R to ensure that SIs and trading venues have a level playing field if acting in a similar way. Ideally this could be achieved by adding to the last sentence of the definition of a ‘price reflecting prevailing market conditions’ in RTS 1 Article 10, “… and where prices are executed at price levels in compliance with the tick size of that financial instrument where applicable”. Alternatively, this could be achieved by a requirement that “substantial and meaningful price improvement” is required to satisfy Best Execution for transactions taking place within an SI. Substantial and meaningful would then be at least a one tick improvement.
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