As part of the MiFID II and MiFIR review, ESMA has drawn up Level 2 measures on which it is holding consultations. Key areas of focus include equity market transparency (still underway), non-equity market transparency (AMAFI / 24-51), the consolidated tape (AMAFI / 24-50), commodities (AMAFI / 24-49), a reasonable commercial basis for the cost of market data (AMAFI / 24-51) and reference data (RTS 23) (AMAFI / 24-53).

Given the Commission President’s keenness to simplify the regulatory framework and promote a competitive European economy, AMAFI stressed three major points in its consultation feedback:

• The goal must always be to make European regulations simpler, not more complicated.
• Changes mean investments – sometimes substantial – for firms but also for regulators, making it important to assess whether they are appropriate.
• New standards, even at Level 2, must factor in EU competitiveness, especially relative to the United Kingdom, which has embarked on a broad-based review of its market rules.