In its support of the development and implementation of the Taxonomy Regulation, EFAMA believes that reporting on the level of alignment with the Taxonomy by non-financial and financial undertakings is essential to strengthening market integrity around sustainability issues.

FIA, ISDA, AFME, ICI, AIMA, EBF and EFAMA (together the Associations) welcome the 
European Commission's (the Commission) timely and temporary equivalence decision from 
21 September 2020 with respect to UK central counterparties (CCPs) and subsequent 
recognition decisions by ESMA of CCPs and the recent temporary equivalence decision for 
UK Central Securities Depositories (CSDs) under CSDR. Together, these steps have provided 
much needed certainty for continued and uninterrupted access to these CCPs and CSDs by 

EFAMA has some concerns with ESMA’s clarifications. In the consultation paper (CP), ESMA seems to have a very broad interpretation of the ‘multilateral systems’ definition under MiFID II and states that ‘systems where trading interests can interact but where the execution of transactions is formally undertaken outside the system still qualify as a multilateral system and should be required to seek authorisation’ (paragraph 36).

We disagree with an extension of its scope to UCITS’ and AIFs’ management companies to the scope of the reporting requirements imposed by MiFIR, Art. 26. This extension would be in breach of the principle of proportionality, as: