The proposal by the European Commission to amend the Benchmarks Regulation represents an overall welcome development in this field, seeking to introduce greater proportionality in the regulation of index providers. While we support the spirit of the proposal, EFAMA advocates retaining certain minimum safeguards applicable to non-significant benchmarks for the protection of users and end investors.

We suggest a number of tweaks to ensure that introducing more proportionality for smaller benchmark administrators does not lead to an incoherent reporting framework:

• De-scope only those non-significant benchmarks which are provided by smaller administrators and keep those provided by larger administrators within scope.

• Align the Benchmark Regulation with the sustainable finance framework, in particular with respect to disclosures and naming conventions.

• Don’t shift reporting obligations from benchmark providers to users. Users must still report on the features of the benchmarks they use under their own sectoral legislation, leaving them in a data vacuum where benchmark statements and other disclosures are not provided.