Several industry associations have published a joint statement expressing concerns about proposed changes to MIFID II and how they will affect energy and commodity market participants. The statement can be found here.

The letter relates to proposals by the European Commission to make further changes after the MIFID II quick fix (see here), which in effect could reverse some of them. The proposals include:

• Reviewing the Ancillary Activity Test again and possibly disallowing its use by larger firms.
• Introducing a “minimum holding period” for commodity derivatives.
• Revising positions limits rules again and extending reporting to emissions allowance derivatives.

The statement is published prior to meetings by the “Trilogue”. The proposals for changes to MiFID II and MiFIR can be found here and here.