Market Structure, Transparency and Reporting

AFME promotes investors’ continued access to a diverse array of execution mechanisms, allowing them to choose the type most suitable for their specific investment needs. In this context, we emphasise the important role that systematic internalisers (SIs) play in European equity markets. SIs use their own capital and balance sheet to facilitate more efficient and better priced execution to their clients, and act as a “shock absorber” by limiting the price impact of client trading. 

SI trading comprised approximately 14% of addressable, price-forming trading activity in 2024, and should be considered as distinct and complementary to matching mechanisms provided by trading venues.

1. MiFIR / MiFID II reforms in the EU and the UK - Implementation Guide for firms operating in wholesale secondary markets
2. The vital role of systematic internalisers (SIs) in European equities markets 
   
3. AFME response to European Commission Consultation – Executive Summary
4. AFME response to the SI regime for bonds and derivatives including Discussion Paper on equity markets

Transaction reporting requirements are subject to review in both the EU and the UK.

In the EU, as part of the EU Markets in Financial Instruments Directive (MiFIR/D II) Review, ESMA’s consultation paper proposed significant changes, including the introduction of a large number of new transaction reporting fields. These changes (if finalised as proposed) would trigger highly complex and burdensome implementation projects for reporting firms that submit MiFID transaction reports.

In June 2025, ESMA launched a call for evidence on a comprehensive approach for the simplification of financial transaction reporting, with the objective to identify how best to enhance efficiency and reduce the costs associated with supervisory reporting, while maintaining a strong level of transparency and ensuring effective oversight from the authorities. ESMA’s final report is expected in July 2026.

In the UK, the FCA published a discussion paper considering all aspects of the UK transaction reporting regime (November 2024), followed by an FCA consultation paper (November 2025). Relevant Policy Statement is expected in the Summer.

AFME’s position is that regulatory reporting is one of the biggest burdens on investment firms, and it is therefore one of the most important areas where work can be done to reduce this burden.

 

1. FCA Consultation Paper 25/32: Improving the UK transaction reporting regime
2. AFME’s consultation response to the FCA discussion paper on "Improving the UK transaction reporting regime”
3. AFME’s consultation response to the ESMA consultation paper on the review of RTS 22 and RTS 24 (January 2025)
4. MiFID Implementation Guide 
5. Joint trade association response to the ESMA Call for Evidence (CfE) on a comprehensive approach for the simplification of financial transaction reporting

EU Commodity Derivatives Regulatory Framework

AFME is actively engaged with EU institutions and policymakers on the future of the EU commodity derivatives framework, with a focus on ensuring that any reforms are proportionate, evidence-based and supportive of market functioning and resilience.

 

Following the European Commission’s consultation on commodity derivatives markets, AFME has intensified engagement with the Commission, Member States and other stakeholders on issues affecting energy and commodity markets, including market volatility, liquidity and regulatory interventions.

 

AFME has coordinated cross-industry advocacy on proposals affecting energy derivatives markets, including discussions around market intervention measures such as gas price caps. Our work has focused on ensuring that policymakers recognise the importance of liquid and globally competitive EU commodity markets for energy security, industrial competitiveness and the green transition.

 

AFME continues to engage with key Commission departments and policymakers on the evolving regulatory agenda for commodity derivatives and wholesale energy markets, including through cooperation with broader industry stakeholders.

 

UK Commodity Derivatives Regulatory Framework

Following the FCA’s reform of the UK commodity derivatives regime, AFME continues to engage closely with regulators and trading venues on implementation of the updated framework, including position limits, exemptions, position management controls and reporting requirements.

 

AFME’s Commodities Committee has worked extensively with the FCA throughout the reform process, providing technical feedback and supporting member engagement through consultations, workshops and ongoing supervisory discussions. A significant number of AFME’s recommendations were reflected in the final UK framework.

 

AFME also continues to engage with UK trading venues, including ICE Futures Europe and the London Metal Exchange (LME), to support proportionate and workable implementation of the revised rules and related market infrastructure changes.

1. AFME and ISDA Response to FCA CP 23/27 on commodity derivatives
2. AFME Response to LME Consultation: Position Limits, Auctions and Rule Changes

Post- and pre-trade transparency regimes have been significantly reformed in both the UK and the EU.

 

The new post-trade transparency frameworks, which came into force in the UK on 1 December 2025 and will apply in the EU from 2 March 2026, introduce revised approaches to the deferred publication of bond trade data. Under both regimes, trades are categorised by factors such as trade size, issue size, issuer type and currency. However, the UK and EU apply different deferral timeframes.

 

Overall, these reforms are expected to materially improve transparency across European markets. In the EU, around 96% of trades by number are expected to receive real-time transparency, compared with approximately 75% in the UK.

 

In the EU, the role of Systematic Internalisers (SIs) has also been narrowed and is now effectively limited to equities. While firms may opt in as SIs for bonds or derivatives, Designated Publishing Entities (DPEs) now perform the post-trade transparency function for those instruments. In addition, all pre-trade transparency requirements for bonds and derivatives have been removed, unless transactions take place on a Central Limit Order Book (CLOB).

 

The UK has introduced similar reforms. The FCA has removed pre-trade transparency obligations for bond and derivative trades executed outside CLOB venues, and the SI regime for bonds and derivatives has been discontinued. Instead, the Designated Reporting Regime (DRR) now applies for post-trade transparency purposes. Further detail is available in AFME’s paper on this topic here.

 

AFME has been closely involved at every stage of the regulatory process shaping these changes. We continue to monitor developments in both the UK and EU, supporting market participants as they transition to the new transparency frameworks and prepare for future reforms.

1. Joint Trade Association agreement on Use of Credit ratings in EU Corp Bond Transparency Regime
2. Liquidity provision and risk management
3. Sov bond transparency analysis and risk offset
4. Corp bond transparency analysis and risk offset
5. AFME and IA aligned on UK bond post- trade transparency model
6. ISDA, AFME, ICMA & EBF Briefing on EC MISP Post‑Trade Transparency