The start of MiFID II on 3rd January 2018 also has an impact on Emissions Allowance Market Participants(EAMP) under MAR. The threshold for an EAMP is defined by MAR Article 17(2) and Delegated Regulation 2016/522, as a group with over 6 million tonnes of carbon a year or over 2430 MW of rated thermal input (see the related documentation for detailed definitions).
From 3rd January 2018, EAMPs are required to comply with several parts of MAR in relation to their allowances, and will in many cases be classified as “Issuers”. This includes publication requirements and others such as the maintenance of insider lists. EEX and the EQS group have collaborated to launch a platform to support compliance, and is announced here.
The recent FCA Marketwatch 55 also discusses the EAMP requirements. It can be found here.