Category: Public

ECSDA response to the Commission targeted consultation on the review of Regulation on the Markets in CryptoAssets (MiCA)

ECSDA response to the Commission targeted consultation on the review of Regulation on the Markets in CryptoAssets (MiCA)

    ECSDA has submitted its response to the European Commission’s targeted consultation on the review of MiCA.

    The review is an important opportunity to build on the experience gained since MiCA was adopted and further develop a European framework that provides legal certainty, supports innovation and enables the responsible growth of digital-asset and tokenised markets, while maintaining a coherent and competitive regulatory environment.

    In its response, ECSDA focuses on a number of areas that will be important for the next phase of Europe’s digital-finance framework:

    • Tokenisation and classification. Tokenised financial instruments should remain subject to the established EU financial-services framework. The use of DLT should not, in itself, change the regulatory treatment of an instrument having the same legal and economic function. Further practical guidance on hybrid, programmable and innovative assets can help provide greater consistency and legal certainty.
    • Digital money for tokenised markets. EMTs, tokenised deposits and central bank money can have complementary roles in the emerging digital financial ecosystem. ECSDA supports a technology-neutral framework that allows these forms of digital money to coexist and develop according to their respective characteristics. In particular, the significance of EMTs should also take account of high-value wholesale transactions, concentration and their role in financial-market infrastructure and settlement, rather than relying predominantly on retail-oriented metrics.
    • A clear functional crypto-asset services perimeter. MiCA should recognise that certain crypto-asset service functions may be functionally linked to, ancillary to or technically necessary for CSDR-regulated services. Mica should provide sufficient clarity to cover activities performed in the context of a CSD’s regulated post-trade services including relevant bring-your-own-wallet (BYOW) models. This would avoid unnecessary duplication between MiCA and CSDR and facilitate the development of DLT-based post-trade infrastructures, while preserving the existing prudential and supervisory safeguards applicable to CSDs.
    • Proportionate rules for emerging services. ECSDA supports a regulatory approach that enables TradFi and DeFi to connect effectively and safely, leveraging regulated financial institutions as trusted access points, and welcomes the reflection on the most appropriate regulatory framework for emerging business models. We support a risk-based approach to crypto-asset lending and borrowing, ensuring that comparable risks are treated consistently across different business models and that regulation reflects their legal and economic substance. Any future framework should also take full account of the existing regulatory requirements applicable to entities already authorised and supervised under sectoral legislation, avoiding unnecessary regulatory duplication while ensuring effective risk management and appropriate protection for users.
    • Legal certainty for tokenised assets. Clear and predictable rules on ownership, transfers, enforceability, custody, insolvency and collateral rights are essential for tokenised markets to develop across borders. ECSDA supports a targeted 28th regime recognising the legal effects of DLT registers, together with an EU conflict-of-law framework for tokens, while avoiding unnecessary harmonisation of national private law.

    A technology-neutral, proportionate and coherent framework can provide the foundations for the next stage of Europe’s digital financial markets — supporting innovation while preserving legal certainty, interoperability and market integrity

    See the full response

Welcome to Vermiculus – ECSDA now counts seven Affiliates

Welcome to Vermiculus – ECSDA now counts seven Affiliates

    We are pleased to welcome Vermiculus as a new ECSDA Affiliate.

    With this addition, ECSDA now counts seven Affiliates: DTCC, GLEIF, Montran, Scorpeo, SWIFT, TMX CDS, and Vermiculus.

    We value the expertise and perspectives our Affiliates bring to the post-trade community and look forward to continuing our collaboration in support of efficient, resilient, and innovative European capital markets.

    Welcome to the ECSDA community, Vermiculus!

ECSDA welcomes the National Depository Center (NDC) of Azerbaijan

ECSDA welcomes the National Depository Center (NDC) of Azerbaijan

    ECSDA is pleased to welcome the National Depository Center (NDC) of Azerbaijan as a new Associate Member of the Association.

    With CSDs representing a range of governance and ownership models, ECSDA provides a platform for the exchange of knowledge, experience and perspectives on developments affecting financial market infrastructures.

    We look forward to engaging with the NDC as part of the ECSDA community and to continuing to promote dialogue, knowledge-sharing and cooperation among CSDs across Europe and the wider region.

    Welcome to ECSDA, NDC!

    NDC website

ECSDA publishes the CSD T+1 Dashboard

ECSDA publishes the CSD T+1 Dashboard

    As Europe’s financial markets prepare for the transition to T+1 settlement by October 2027, ECSDA is publishing the first version of its CSD Implementation Overview Dashboard — a living document that will be updated regularly as preparations advance.

    This Dashboard is designed to give markets the information they need: a clear, consolidated view of what will be implemented by CSDs in each market, enabling participants, issuers, and investors to prepare accordingly.

    Transparency, coordination, and timely information sharing are key to a smooth T+1 transition — and this Dashboard is ECSDA’s and CSDs’ contribution to that effort.

    Disclaimer:
    In case of discrepancies between this table and the latest official communication of the relevant CSD, the latter prevails. ECSDA accepts no liability for the content of this Dashboard, which is provided for the purposes of a high-level overview across European markets and ensuring transparency in advancement of the preparation, allowing CSD participants and other FMIs to prepare the move in an orderly way.

    Link to the Dashboard – Last updated: 29/06/2026

Gating Event FAQs & Best Practice Guide Published

Gating Event FAQs & Best Practice Guide Published

    The EU T+1 Industry Committee has published the Gating Event FAQs and Best Practice document, marking an important step in the industry’s preparation for T+1 settlement by October 2027.
    This document provides practical guidance on the implementation of the Gating Event mechanism for Securities Financing Transactions (SFTs), a key tool designed to address the intraday liquidity challenges arising from the move to T+1.

    Access the full document – Gating Event – FAQs and Best Practice

ECSDA Affiliates’ community continues to grow!

ECSDA Affiliates’ community continues to grow!

    At the meeting of the ECSDA Senior Industry Council hosted by Euroclear France in Paris, the ECSDA Board officially welcomed DTCC, GLEIF, TMX CDS – The Canadian Depository for Securities Limited, and Vermiculus as new ECSDA Affiliates.

    Their arrival further strengthens our Affiliate community and reflects the growing interest of market infrastructure stakeholders in engaging with ECSDA and its members.

    They join our existing Affiliates: Montran, Scorpeo, and Swift – Link to the list of ECSDA Members and Affiliates

    We look forward to working together and fostering dialogue across the post-trade ecosystem.

ECSDA answer to the review of the Shareholder Rights Directive (SRD)

ECSDA answer to the review of the Shareholder Rights Directive (SRD)

    ECSDA welcomes the review of the Shareholder Rights Directive (SRD) as an opportunity to further enhance transparency, operational efficiency, and cross-border harmonisation in the exercise of shareholder rights across the EU.

    • While SRD II has improved shareholder identification, information flows, and shareholder participation, ECSDA notes that broader capital market integration has also been driven by infrastructure modernisation, common standards, and technological developments.
    • ECSDA strongly supports the harmonisation — or removal — of shareholder identification thresholds and the harmonisation of key general meeting dates in order to reduce fragmentation, operational complexity, and legal uncertainty in cross-border scenarios.
    • The paper advocates for more standardised and digitalised processes for evidence of entitlement, voting confirmation, and transmission of information, supported by ISO standards and fully digital communication channels to improve cross-border STP and shareholder participation.
    • ECSDA supports the introduction of a more functional and harmonised definition of “shareholder” to reduce inconsistencies arising from divergent national legal frameworks and ownership concepts across Member States.
    • ECSDA generally supports extending the scope of SRD, including to unlisted and digital securities, while stressing the need to ensure operational feasibility, proportionality, and legal consistency across the regulatory framework.
    • The paper also supports the establishment of a “Golden Operational Record” maintained by Issuer-CSDs as a centralised and reliable source of corporate event information, improving data integrity and operational efficiency across the custody chain.
    • ECSDA underlines the continued systemic importance of CSDs and intermediaries in ensuring scalability, resilience, standardisation, and secure information flows within integrated European capital markets.

    Read the full answer.

ECSDA view on the Settlement Finality Regulation EC Proposal

ECSDA view on the Settlement Finality Regulation EC Proposal

ECSDA recognises the importance of ensuring that the Settlement Finality framework remains both technologically advanced and neutral across traditional infrastructures, DLT, and other emerging technologies. It also supports targeted harmonisation where necessary to enhance consistency and strengthen legal certainty.

The settlement finality framework is a core pillar of the safety of settlement and payment systems in the EU and has proven its resilience in well-known crisis situations. Any amendment should, therefore, be approached with caution. The application of the Settlement Finality Legislation provisions effectively modifies how standard insolvency law operates, which may affect the position of other creditors of the insolvent entity. Such a change of the standard insolvency process is justified for the purposes of financial stability for systems with systemic relevance.

This underscores the importance of carefully assessing whether changes to certain core definitions, such as the finality moments, are indeed necessary, as well as ensuring a consistent set of system designation criteria that preserve systemic relevance as the key principle justifying the exceptional insolvency regime.

ECSDA welcomes the reform’s general objectives. However, SFD has already clearly defined all relevant aspects of settlement finality concerning CSD activities. Therefore, transforming the SFD into a more rigid instrument is not necessary to achieve further harmonisation in our area. And we need to remind that other barriers essential to be addressed remain untouched (see AMI-SeCo Post-trade barriers report).

 

Read the full document.