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The FCA accelerates wholesale market reviews promises

FCA logo
FCA logo

The Financial Conduct Authority’s new consultation starts the delivery of two structural reforms for equities: it proposes allowing Multilateral Trading Facilities (MTFs) to deal as principal on their own order books, chiefly letting them cross blocks within a unique legal entity and asks for feedback on widening the reference-price waiver.

The FCA says: “In this consultation we propose three main changes… removing the prohibition on an investment firm to execute clients’ trades on the MTF they operate on a matched principal trading basis… [and] permitting trading venues operating under the reference price waiver to use a broader set of prices than just the primary market” .

Under the current Markets in Financial Instruments Directive (MiFID II) derivation, an MTF operator may not interpose itself between two clients on its own venue. The FCA concedes that the ban “resulted in additional costs for the operators’ group entity and their clients” and that lifting it “will reduce complexity and… deliver greater simplicity in the execution of trades”. The FCA therefore proposes to abolish the rule in order to let venues compete with Systematic Internalisers (Sis) when crossing blocks.

The FCA says: “This will enable more firms to offer competitive execution services without the need for contrived legal structures, thereby fostering innovation and reducing costs for end users”

On transparency waivers, the FCA writes: “We therefore propose to allow trading venues to source their reference price from a wider set of trading venues, including those not currently qualifying, and to combine prices from multiple venues”.
It also asks whether the waiver should move from a system-level to an order-level basis so that “mid-price, dark orders” can rest inside a lit book. The stated aim is to give venues “similar latitude” to dealers that reference their own SI quotes, improving competition without undermining price formation.

A FIX EMEA poll conducted in April saw market participants vote that the growth of bilateral trading is their top worry, prompting the FCA to “pledge caution” in any future equity reforms.
Read more: FCA pledges caution as industry voices concern over rise of bilateral trading.

The equity discussion paper focuses on market structure. It flags a structural shift. The FCA says: “An increasingly significant role for negotiated bilateral trading and a sustained decline in the share of trades executed on central limit order books (CLOBs)” is raising doubts about “whether fragmentation could impact the effectiveness and attractiveness of United Kingdom equity markets.”
CLOBs, the FCA  notes, have long underpinned transparent price discovery, yet their share of addressable volume has fallen from 47 per cent in 2018 to 29 per cent in May 2025, prompting some of the FCA’s market contacts to warn that the trend “may be affecting, or could in future affect, the visibility of addressable liquidity and the resilience of price formation.”
On that basis the regulator asks whether the shrinking CLOB footprint is already distorting price signals and what steps might reinforce the order-book model’s role in setting public benchmarks.

The Financial Conduct Authority is clearly aware of the current debate around measuring accessible liquidity. “‘Addressable liquidity’ is not defined in regulation but is commonly used in the market to mean liquidity that participants could interact with,” the FCA says, before warning that studies which count only on-venue trades “could distort perceptions of the United Kingdom’s market depth and attractiveness” now that a growing share of flow is executed bilaterally. The FCA “invite[s] participants’ feedback on whether the reporting or the dissemination of trade data is limiting the ability of firms or issuing companies to fully understand the liquidity in the market” and, asks whether new compulsory trade-report flags or stricter use of existing ones are needed to isolate truly price-forming bilateral activity.
Read more: Aquis study prompts calls for standardised FIX flags .

Comments must be sent to the FCA by 10 September 2025; the FCA plans to “finalise the changes… in a policy statement in Q4 2025”. An exhaustive equity-transparency consultation remains scheduled for 2026. According to the FCA’s website notice, these reforms are intended to “support competition, reduce unnecessary complexity and improve market resilience”.

Barclays signals focus on digital execution with Goldman hire

Anne Marie Darling, co-chief operating officer and Barclays Execution Services (BX) co-chief executive officer, Barclays
Anne Marie Darling, co-chief operating officer and Barclays Execution Services (BX) co-chief executive officer, Barclays

The bank has appointed Anne Marie Darling, who ran Goldman Sachs’ Marquee trading analytics platform for institutional clients, as co-chief operating officer and Barclays Execution Services (BX) co-chief executive officer alongside Craig Bright.

The pair are based in London, and take on the role following a two-month transition process. They replace Alistair Currie, who has been group chief operating officer since 2023 and with Barclays since 2017.

BX is Barclays’ service provision unit for the company’s UK and international operations, with a focus on increasing efficiency and scaling the business. It has previously been involved in developing electronic trading capabilities within the equities division.

In the first three months of 2025, equity trading revenues were up 59% quarter-on-quarter (QoQ) and just 9% year-on-year (YoY) to €1.1 billion at the bank. A further €2 billion was reported in fixed income trading, making for a more drastic 82% QoQ and 21% YoY increase.

The bulk of Darling’s more than 30-year career has been spent at Goldman Sachs. She was most recently a partner at the firm, before which she was managing director and vice president.

READ MORE: Goldman Sachs partners with QI to offer macro analytics

Bright has been promoted from chief information officer, a role he has held since 2020. Prior to this, he was group chief information officer for Westpac bank in Australia and spent seven years at Citi in New York, first as managing director of global consumer infrastructure and head of North America before becoming chief technology officer for global consumer banking in 2016. He has more than three decades of industry experience.

Venkatakrishnan noted, “Craig and Anne Marie each have a vast and rich professional experience and complement each other well. We will benefit from their collaborative leadership.”

Via LinkedIn, Currie commented, “They will be outstanding in their new roles and will continue to drive new capabilities across the bank – underpinning customer experience, productivity, resilience, operating control, digital, data and AI capabilities and much more.”

Jane Street banned from India operations

Jane Street
Jane Street

Jane Street made INR 48.4billion (US$556.7 million) in illegal gains as a result of index manipulation, according to the Securities and Exchange Board of India (SEBI).

Pending further investigation, SEBI is impounding Jane Street’s (JS Group) alleged unlawful gains, requiring the company to deposit the funds in an escrow account at the Scheduled Commercial Bank in India. Any open positions in exchange traded derivatives contracts must be closed within three months or at expiry.

Its interim order states, “entities are restrained from accessing the securities market and are further prohibited from buying, selling or otherwise dealing in securities, directly or indirectly. If the Entities have any open position(s) in any exchange traded derivative contracts, as on the date of this Interim order, they can close out/square off such open positions within 3 months from the date of order or at the expiry of such contracts, whichever is earlier.”

The group has disregarded a caution letter issued by the National Stock Exchange in February, advising against taking large cash-equivalent positions and using certain trading patterns, and continues to run very large cash-equivalent positions in index options, SEBI has said in an interim order.

In December 2024, SEBI stated that it identified abnormally high or low volatility on weekly index options expiry days and that certain entities were running large cash-equivalent risks, particularly on expiry days. This followed an April investigation into Jane Street’s reported unauthorised use of proprietary trading strategies in Indian options markets.

Of the 18 trading days analysed as part of the investigation, SEBI notes that JS Group’s operations had evidence of an intraday index manipulation strategy. On the remaining three days, evidence of extending the market close was reported.

In one such case, on 17 January 2024, actions from the group pushed up BANKNIFTY index prices and it subsequently built large short positions. These were then reversed and sold, pushing down the index and producing larger options positions and profits that offset and intraday cash and futures trading losses.

JS Group’s strategy of taking very large trading market share facilitates this price-moving.

READ MORE: Jane Street took 10% of of US equity market in 2024

SEBI comments, “dealing in multiple segments across cash equities, stock futures, index futures, and index options simultaneously is certainly not by itself a breach of any regulation.

“However, what sets apart the trading pattern of the JS Group as described above as prima facie being manipulative, is the intensity and sheer scale of their intervention in the underlying component stock and futures markets, the rapid reversal of these large and aggressive trading in cash and futures without any plausible economic rationale, other than the concurrent activity in and impact on their positions in the BANKNIFTY index options markets.

“JS Group was exploiting its size and sheer volume to move the underlying BANKNIFTY index level, so as to benefit from its much larger actions or positions in the BANKNIFTY index options segment.”

JS Group told SEBI on 30 August 2024 that the trades were executed to remove unwanted delta or manage overall delta, statements which the regulator calls “bland”.

JS Group has previously been involved in a lawsuit surrounding its Indian options strategy, suing Millennium Management and two of its former employees, Doug Schadewald and Daniel Spottiswood, who jumped ship to the competitor in 2024. The group alleged that the traders had taken the strategy with them – a strategy that produced US$1 billion in profits in 2023.

A Jane Street spokesperson commented, “Jane Street disputes the findings of the SEBI Interim Order and will further engage with the regulator. Jane Street is committed to operating in compliance with all regulations in the regions we operate around the world.”

Barclays reorganises APAC IB

Avinash Thakur, APAC head of investment banking, Barclays
Avinash Thakur, APAC head of investment banking, Barclays

Barclays has reorganised its APAC investment banking business after naming Avinash Thakur as head of the division.

Thakur had been managing director and head of capital markets financing for the region since 2014.

On the slew of promotions, he commented, “Asia Pacific is crucial to our global growth plan, and this team will drive the next phase of our ambition with clarity, deeper client relationships, and stronger collaboration across markets through focussed execution.”

Richard Satchwell has been promoted to APAC head of capital markets financing, after four years as CEO and head of investment banking for Australia. Relocating to Singapore, he will lead debt and equity financing.

Duncan Connellan will take on the Australian head of investment banking role, while David Henderson has been named CEO of the Australian business.

In India, Arun Saigal’s role as head of financing and M&A has expanded to lead investment banking. Pramod Kumar, CEO of Barclays India, is additionally taking on the role as APAC vice chairman of investment banking.

Ee-Ching Tay, head of investment banking for Southeast Asia, is now also APAC head of M&A.

Year-to-date 2025, Barclays ranks fifth in APAC ex-Japan M&A revenues with US$58 million and a 5.3% market share. The bank has moved up seven places in Dealogic’s rankings compared to this time last year. By volumes, however, Barclays did not break into the top ten.

In the IPO market Japan ranked fourth globally between May 2024 and April 2025, with US$9 billion issued in JPY.

US banks boosted trading positions ahead of new lenient stress test results

Mike Mayo
Mike Mayo, Wells Fargo.

Top US banks redeployed capital into their trading businesses ahead of the Federal Reserve’s 2025 stress test results, which softened the worst-case stress scenario for a market downturn.

As US banks prepare to release their second-quarter earnings, results from the Federal Reserve’s annual stress tests, on 27 June, free additional risk capital at major US banks.

Tallies, provided by Risky Finance, of trading asset trends across major US banks, including JP Morgan, Goldman Sachs, Morgan Stanley, Citigroup, Wells Fargo and Bank of America, show total trading assets on US banks’ books have been accelerating upward. This increase was already pronounced from the end of 2024 into 2025 with the arrival of the new US administration; JP Morgan total trading assets grew from US$637 billion at the end of 2024 to US$873 billion at the end of Q1 2025, and from US$579 billion to US$604 billion for Goldman Sachs.

Screenshot

Goldman Sachs was the clearest victor of this year’s Fed’s less stressed scenario, with projected trading loss shrinking to just US$300 million, compared to US$18 billion in the previous year. The bank benefited from tighter internal risk controls and methodological easing in the Fed’s stress testing, such as the removal of private equity investments from its market shock scenario.

Betsy Graseck
Betsy Graseck, Morgan Stanley.

Morgan Stanley analyst, Betsy Graseck, highlighted the impact of recent trading dynamics: “Capital markets are back. We expect 2Q25 Equities markets revenues to be robust at +10% year-over-year. Industry data supports revenues potentially coming in even higher, with off-exchange volumes up +83% y/y in April, +45% y/y in May, and +80% y/y in June.”

Equity securities held by banks also reached record highs as of 31 March 2025, with Morgan Stanley owning $US127 billion worth of stocks at the time, Bank of America held US$84 billion worth of stocks, JP Morgan US$241 billion, and Goldman US$149 billion.

Screenshot

The relief provided by the stress tests has direct implications for the banks’ capital allocations. Morgan Stanley’s research estimated that “excess capital at large-cap banks rose by 26% post-stress test, increasing from US$156 billion to US$197 billion, driven by a 60 basis points decline in the stress capital buffer (SCB) at the median bank.”

Goldman Sachs, benefiting most prominently from the stress test methodology adjustments, reduced its core equity tier one (CET1) capital requirement from 13.6% previously to just 10.9% of risk-weighted assets. It is its lowest since the Fed’s current regime began in 2020.

JPMorgan also saw substantial benefits from the latest stress test, with its stress capital buffer (SCB) declining by eighty basis points, from 3.3% to 2.5%. Morgan Stanley analysts also noted JPMorgan’s strong potential Q2 trading results: “We expect JPMorgan’s equities trading revenue growth to reach approximately +8% year-over-year, supported by increased market activity and client-driven transactions.”

Citigroup experienced a more moderate decline in its SCB, dropping fifty basis points from 4.1% to 3.6%. Morgan Stanley’s analysis indicated that Citigroup would see revenue growth driven by fixed income, currencies, and commodities (FICC) markets, with “revenues expected to increase +8% year-over-year, benefiting from improved market conditions and trading volume expansions.”

Mike Mayo
Mike Mayo, Wells Fargo.

Wells Fargo analysts, led by Mike Mayo, described the overall fed stress test scenario as “the least stressful this decade,” attributing the positive outcomes to “lower loan losses, lower private equity losses, and less global market shock.” They further emphasised that capital markets-focused banks such as Goldman Sachs, JPMorgan, and Citigroup stand to gain significantly, given their ability to redeploy substantial excess capital into core trading activities.

Morgan Stanley noted that Goldman’s strategy to focus heavily on financing revenues will further boost its performance:
“For equities markets, we expect revenue growth of +16% y/y versus consensus of +13%, given Goldman’s focus on growing financing revenues,” said Graseck.

With second-quarter earnings imminent, both Morgan Stanley’s and Wells Fargo’s analysts say the banks will have the opportunity to clarify how they will apportion this freed-up capital between further growth of their trading asset bases or returns to their shareholders.

Lanne leads BeNeLux at Citi

Hubert Lanne, head of market sales France and BeNeLux, Citi
Hubert Lanne, head of market sales France and BeNeLux, Citi

Citi has promoted Hubert Lanne to head of market sales for Belgium, the Netherlands and Luxembourg (BeNeLux).

Market revenues at the bank were up 12% year-on-year in Q1 2025, with a reported US$6 million.

Based in France, Lanne takes on the responsibilities in addition to his existing role as head of markets sales for France. He has been with Citi since 2005, leading hedge funds rates sales.

big xyt: Navigating fragmented markets

Mark Montgomery, CCO, big xyt.

Navigating fragmented markets: the importance of independent TCA in enhancing execution outcomes

By Mark Montgomery, CCO, big xyt

Mark Montgomery, CCO, big xyt.

In today’s increasingly fragmented and complex market landscape, buy-side trading desks face the dual pressure of achieving execution quality and maintaining regulatory compliance, all while navigating complex liquidity environments. Traditional transaction cost analysis (TCA), often reliant on broker reports and static benchmarks, is no longer sufficient to meet the demands of today’s execution landscape.

Market participants are instead turning towards independent, high-precision analytics that offer a more granular view of market behaviour – supporting not just regulatory mandates, but more informed trading decisions.

Fragmentation and Complexity: Structural Challenges for the Buy-Side

Modern equity markets operate across a broad spectrum of venues including lit exchanges, dark pools, systematic internalisers and periodic auctions. Each presents unique characteristics in terms of liquidity access, price discovery and transparency. This dispersion has introduced new layers of complexity into execution workflows, particularly for buy-side firms aiming to minimise slippage and market impact while accessing sufficient liquidity.

The reliance on broker-provided TCA poses a risk in such an environment. Without a neutral, data-driven benchmark, it becomes difficult to assess whether execution strategies are achieving their intended outcomes or simply aligning with broker capabilities. Independent analytics offer an alternative lens – helping to validate execution quality and inform future trading behaviour based on actual market conditions.

Market Volume by Trade Category

Why Independence Matters

The value of independent TCA lies in its ability to remove conflicts of interest from the measurement process. An analytics provider that does not participate in trading or route flow is better positioned to offer objective insights into how orders are executed, where slippage occurs, and whether broker routing decisions align with client performance goals.

This independence becomes particularly important in multi-broker environments where assessing comparative performance is critical. It allows trading desks to ask more rigorous questions about venue selection, liquidity access and execution timing – questions that may not be answered fully by internal or broker-led reporting.

Broker Performance


The Importance of Data Transparency and Quality

Data transparency is foundational to effective TCA. Access to raw tick data – particularly Level 3 order book information – enables a detailed reconstruction of the market environment at the time of execution. This level of granularity supports analysis not just of price outcomes but of market dynamics around each trade.

Order Book Replay

Robust data quality controls are equally essential. With the sheer volume of global trading activity, systematic cleaning, validation and normalisation processes are needed to ensure consistency across venues. Independent analytics platforms that integrate these capabilities reduce the operational burden on trading desks and support more accurate, comparable metrics.

From Compliance to Continuous Improvement

TCA remains a central component of regulatory frameworks like MiFID II, which require firms to demonstrate best execution. However, the role of TCA is expanding beyond compliance. Increasingly, it is being used to inform strategic questions: Are participation rates optimised for current liquidity conditions? Which venues are most suitable for different order types? How do execution outcomes vary across time-of-day or volatility regimes?

When aligned with these goals, analytics become a tool for continuous improvement. They help identify areas for strategy adjustment and provide the evidence needed to justify tactical changes, such as altering venue preferences or rebalancing between aggressive and passive execution styles.

Real-Time and Intraday Insights

While many TCA processes operate on a T+1 basis, real-time analytics are playing a growing role – particularly for desks managing high-touch or algorithmic strategies. Intraday visibility into order execution, liquidity fragmentation and off-book trading patterns enables quicker decision-making and proactive risk management.

Volume and Volatility (Historical vs. Intraday)

This is particularly relevant in volatile market conditions where trade-offs between immediacy and market impact shift rapidly. Intraday alerts on unusual trading patterns or liquidity imbalances can inform whether to pause or adjust execution strategies mid-session.

Data Science and Adaptive Models

Execution analytics is also evolving with the integration of advanced data science techniques. Machine learning and clustering algorithms can segment securities not just by sector or size, but by shared trading behaviours, such as spread dynamics, turnover patterns or typical market impact curves. This allows for more targeted strategy development and a move away from overly broad classifications that may not reflect trading realities.

Adaptive models are especially useful in markets where historical relationships can break down quickly, as was observed during recent episodes of extreme volatility or structural shifts in liquidity provision.

Flexibility in Access and Integration

Buy-side firms differ significantly in how they structure their trading and analytics functions. Some may require dashboard visualisations for pre-trade planning, while others embed TCA directly into their OMS or EMS workflows. Others, particularly quantitative teams, prioritise access to raw data and APIs for deeper, customised analysis.

A flexible architecture that accommodates these varied needs – through API endpoints, file delivery options or browser-based tools – can support a more integrated approach to execution analysis. It also reduces reliance on internal infrastructure, which can be costly to build and maintain, especially when handling large-scale tick data.

A Broader View of Execution Performance

Execution quality is multi-dimensional. It encompasses cost, timing, market impact and relative performance against benchmarks. As buy-side firms look to balance these factors across increasingly diverse market conditions, independent TCA plays a key role in maintaining discipline and visibility.

By grounding execution decisions in data rather than anecdote, firms can foster a more accountable and performance-oriented trading culture. This not only helps meet regulatory expectations but also supports better outcomes for investors over time.

Looking Ahead

As trading markets continue to fragment and technology continues to evolve, the need for robust, transparent execution analytics will only grow. For the buy-side, this means prioritising solutions that offer independence, data quality and analytical depth – while remaining agile enough to adapt to new trading behaviours and regulatory pressures.

Independent TCA is no longer a luxury – it’s a necessary component of a modern execution strategy. By embedding it into daily workflows and decision-making processes, firms can gain a clearer understanding of market mechanics, improve execution outcomes and stay ahead in a competitive and complex trading environment.

TCA Portal

Best Execution by Venue

Single Order TCA Report from Order List

 

Euronext-Athens’ deal gets cautious welcome from analysts

European bourse consolidation shows no sign of slowing: Euronext has proposed a €399 million all-share takeover of Hellenic Exchanges-Athens Stock Exchange. Shareholders might have expected more fixed income, low volume business growth with the “innovate 2027 plans”.

Michael Sanderson, analyst at Barclays, estimates it will only bring low value to the group.
He said in a note published 2 July: “Assuming that negotiations are completed and any transaction is concluded in 2026, based on Bloomberg consensus for Athex future earnings we estimate accretion would be lower than 2% on full year 2028 estimate base.” But added that Euronext track record at integrating cash market exchange acquisition means that “This type of market consolidation should be well received by shareholders, even if the accretion is only very limited”.

Hubert Lam, and Christian Holstein, analysts at Bank of America agreed: “ENX has a strong track-record of achieving synergy targets; it achieved 130% and 115% of initial targets in the Irish and Oslo Bors acquisitions, respectively”

Market participants might have expected more focus following the launch of the “Innovate for growth 2027” in November 2024. Euronext had said: “Our strategy relies on three priorities: (i) accelerate growth in non-volume business, (ii) expand the FICC1 trading and clearing franchise and (iii) build upon our leadership in trading” but had also stressed that they would continue to “execute external growth opportunities, in line with its investment criteria.”

Read more: Euronext reports Q3 revenue growth; announces 2027 goals

Euronext said it is in talks with the Athex board about buying up to 100 per cent of the Greek market operator but stressed that any formal bid will depend on due diligence and regulatory clearances. Euronext’s indicative terms offer Athex investors 21.029 of their shares for one new Euronext share, implying a price of €6.90 and valuing the bourse at about €399 million based on Euronext’s €145.10 close on 30 June.

Deutsche Bank is advising Euronext on the deal, Athex declined to comment.

“There can be no certainty, at this stage, that this would result in any agreement or transaction,” the exchange operator cautioned, adding that a deal would “deliver on Euronext’s ambition to consolidate European capital markets with growth and synergy opportunities.”

Athens would become Euronext’s ninth exchange with a combined market value over €6 trillion and giving the group, which already handles roughly a quarter of all lit cash-equity trading in Europe, a foothold in the south-eastern corner of the Euro zone.

The potential acquisition comes as Greek stocks and bonds have been outperforming the benchmark. Athex composite is up about 13 per cent this year after a near-40 per cent surge in 2024. In 2024 Greek bond spreads over equivalent bunds traded below that of French bonds, quite the reversal from the European crisis of the early 2010s. Volume on the Athens lit market is averaging €3 billion a month this year as per BMLL data.

Euronext carries on its consolidation strategy: It bought the Irish Stock Exchange for €137 million in 2018, Oslo Børs VPS in 2019 and Italy’s Borsa Italiana for €4.4 billion in 2021, while rival SIX has just absorbed Aquis to bolster its own pan-European footprint.

No Danish Compromise for BNP Paribas

Sandro Pierri, CEO, BNP Paribas Asset Management
Sandro Pierri, CEO, BNP Paribas Asset Management

BNP Paribas has finalised its acquisition of AXA Investment Managers (AXA IM) and clarified its leadership structure going forward.

The firm has not been able to employ the ‘Danish Compromise’, under which banks do not have to deduct the value of insurance subsidies from their capital. In May, the ECB stated that this would not be applicable to asset management undertakings.

READ MORE: BNP’s Axa IM acquisition to close in July despite ECB shutting capital loophole

BNP Paribas has estimated that its common equity tier 1 (CET 1) ratio will fall by approximately 35 basis points as of Q3 2025 following the acquisition, adding that “discussions with supervisory authorities are still ongoing.”

Sandro Pierri, CEO of BNP Paribas AM, is now also CEO of AXA IM. Marco Morelli, formerly executive chairman of AXA IM, is now a chairman of both companies.

The pair report to Renaud Dumora, deputy chief operating officer, head of investment and protection services, and chairman of BNP Paribas Cardif.

On the announcement, Dumora said, “Morelli and Pierri will spearhead the integration process of BNP Paribas’ asset management activities to form, with all teams, a European industrial platform, leader in traditional and alternative asset management and leader in insurance management. I have every confidence in their ability to make this industrial project a success.”

BNP Paribas now holds more than €1.5 trillion in assets under management across Europe.

ESMA opts for leniency in T+1 roadmap

Giovanni Sabatini, independent chair, EU T+1 Industry Committee
Giovanni Sabatini, independent chair, EU T+1 Industry Committee

The European Securities and Markets Authority (ESMA) has released its high-level roadmap for T+1 settlement, identifying 51 recommended actions as high priority and angling for securities financing transactions (SFTs) CSDR penalty exemptions.

The authority specifies that adherence to the standard operational timetable it outlines is “strongly encouraged” rather than legally required. However, it stresses that not harmonising with the standard could cause financial detriment to other market participants.

A proposal to amend Article 5(2) of CSDR, making SFTs executed on trading venues exempt from T+1 settlement obligations and temporarily suspending cash penalties, was published by the European Commission in February. A political agreement on this was reached on 18 June, after calls for clarification by market participants.

READ MORE: Clarity needed around Europe’s SFT T+1 exemption

Cash penalties are enforced under CSDR if a settlement fails, and are intended as a deterrent. The scope of the penalty is determined by the asset type, liquidity of the financial instrument, type of transaction and the duration of the fail.

Daniel Carpenter, CEO of Meritsoft, a Cognizant company, argues, “while the cash penalties can serve to incentivise firms to be ready for October 2027, it can also adversely affect a trader’s ability to source liquidity if counterparties believe the penalty of a trade fail is too costly. CSDR penalties are costing the industry around €70m a month [per Firebrand Research] and could well increase under T+1 timelines, especially as the EU moves to reinvigorate its capital markets through the Savings and Investment Union.”

Currently, CSDR penalty exemptions apply if the underlying cause of the fail is not attributable to the transaction participants or is attributed to operations that are not considered trading, for transactions where the failing participant is a central counterparty (unless the CCP does not interpose itself between the counterparties in a transaction) or when insolvency proceedings have been opened against the failing participant.

In the US, penalties for late settlements have not been imposed under T+1.

Francisco Béjar, head of CSD at SIX, commented, “CSDR penalties [have] the potential to add significant extra cost if moving to shorter settlements increases the volume of trade fails in the EU. We will be working closely with market participants to ensure they are ready and deliver high trade settlement rates so this step isn’t necessary. But it’s a sensible backup option if the market needs this.”

Carpenter added, “the possibility of suspending CSDR cash penalties during the transition to T+1 signals that EU officials are concerned about the likely increase in settlement fails as the markets adjust to the new settlement timeframe,” argues

ESMA has also called for changes to its guidelines on standardised procedures and messaging protocols under CSDR. Following its consultation paper on the amendments, the authority plans to submit draft amendments to CSDR in Q1 2026. Final guidelines are expected to be published in Q3 2026.

Elsewhere, acknowledging that divergence in settlement cycles across asset classes and geographies could cause liquidity management, performance and regulatory compliance issues for investment managers, the roadmap advises that there should be no penalties where moving to a T+2 cycle is not possible for investment funds.

The majority of investment funds currently settle on a T+3 or T+4 basis, ESMA states. While subscription and redemption should be reduced to T+2 where possible, the authority notes that this reduction may not be a practical change before the T+1 go-live.

Further minimising penalties for investment managers, ESMA states that regulatory clarification should be introduced to ensure that cash breaches caused by settlement misalignment are categorised as passive and non-reportable.

Giovanni Sabatini, independent chair of the EU T+1 Industry Committee, concluded, “we urge all market participants to review the recommendations, assess the impact on their systems and procedures and start planning how they want to prepare for the transition to T+1.”