ALFI supports the proposal for a review of MiFIR adopted by the EU Commission on 25 November 2025. Its content is in line with a number of requests expressed by ALFI in its previous responses to ESMA consultations, in particular on (i) the alignment of the derivatives trading obligation (DTO) with the clearing obligation (CO) and (ii) the simplified definition of the share trading obligation (STO). ALFI is also in favour of a consolidated tape (CT) providing pre-trade data.

Derivatives clearing

The response to the consultation on initial margin model validation (IMMV) has been the opportunity to remind to EBA/ESAs the specificities of the investment funds compared to banking brokers, and that the usage of the well-established ISDA SIMM standard model should not lead to an unnecessary approval by the NCA, and neither burdensome back-testing measures. A relief has been asked for entities eligible to UMR phase 6 in September 2022.

Besides, ALFI advocated for an extension of the temporary equivalence to access UK CCPs, that has been finally granted by the European Commission until June 2025. The ALFI proposal to exempt UK ETDs from the calculation of OTC exposure in a post-Brexit scheme received support from ESMA.

Settlement discipline

Over the course of the past two years, ALFI has been playing a leading advocacy role towards the EU public bodies on the CSDR file, underlining the specificities of the asset management industry.

In line with the ALFI position paper on the Settlement Discipline Regime (SDR) published in July 2021, a number of arguments were exchanged directly with ESMA to advocate for a postponement of the mandatory buy-in regime, which was granted mid-December 2021. Before Christmas, a best practices document on the CSDR SDR was published to prepare the application of the cash penalties in February. This document represents a joint effort between various ALFI working groups covering CSDR and fund accounting with the contribution of the ALFI Depositary Forum. It has been a collaborative team work across the association in a relatively short period of time.


François Baratte, Senior Industry Affairs Adviser