ECSDA welcomes CPMI-IOSCO’s aim to clarify expectations under PFMI Principle 15 and improve consistency in how FMIs address General Business Risk (GBR). We support guidance that supplements rather than reopens the PFMI and that remains outcomes-based, proportionate, and technology-neutral.

In that context, we particularly highlight that European CSDs already operate under a stringent, detailed CSDR prudential and operational framework specified in the technical standards. Although we may not expect other jurisdictions to fully endorse the European approach as applicable to all other regions through the international guidance, the clarity and accuracy of the relevant European provisions for CSDs should serve as an example of a high-quality implementation of the international guidance. The final guidance should pursue high-level international alignment and aspire for further clarity, providing regional flexibility rather than imposing parallel, potentially conflicting obligations.

We suggest that the final guidance:

• Clarifies scope and interactions with other risk families and with existing EU law under CSDR, notably RTS (EU) 2017/390 (prudential requirements) and RTS (EU) 2017/392 (authorisation, supervisory and operational requirements).
• Maintains flexibility in tools, focusing on identification and governance of GBR and not prescribing specific measurement models, vendor tooling, or external assurance that could be disproportionate for CSDs.
• Adjusts transparency, ensuring disclosures are on a legitimate “need-to-know” basis and do not require publication of commercially sensitive information or routine notice of minor technical changes.
• Calibrates LNAFE expectations to recognise (i) the low-frequency/high-impact-nature of certain shocks, (ii) the existing EU CSDR prudential requirements, recovery and winddown frameworks, and (iii) that capital should not be duplicated for the going concern, ‘business as usual’ risk management and recovery and orderly wind-down phases.

Read the full response

ECSDA welcomes the CSD of the National Bank of Romania as a new full member of the Association. We welcome and extend our congratulations to the National Bank of Romania. ECSDA looks forward to supporting our new and present members on their journey to building an even more interconnected and modern European financial markets infrastructure.

On that occasion, Anna Kulik, the ECSDA Secretary General, stated: “We look forward to welcoming the CSD of the National Bank of Romania as the Association’s new Member. ECSDA is pleased to continue supporting the CSDs of all types of governance or ownership models. The exchange of knowledge within the Association, as well as the development and implementation of joint standards within ECSDA, contribute to building an even more interconnected, modern and safe financial infrastructure, addressing the needs of capital markets in relevant jurisdictions, and supporting the global competitiveness of European economies. We are delighted to see that the National Bank of Romania CSD decided to be part of the joint industry effort. ”

The ECSDA Board of Directors unanimously elected Edwin De Pauw, Euroclear Bank, as Vice-Chair of the Association. ECSDA congratulates him on this appointment and looks forward to continued close cooperation within the Board.



The Board of Directors is now composed as follows:

• Mark Gem, Clearstream Europe AG, ECSDA Chairperson
• Olga Jordao, Euronext Securities, ECSDA Vice-Chair
• Edwin De Pauw, Euroclear Bank, ECSDA Vice-Chair
• Georg Zinner, OeKB CSD, ECSDA Treasurer
• Indars Aščuks, Nasdaq CSD SE
• Francisco Béjar Nuñez, Iberclear/BME/SIX
• Geert Desmedt, Euroclear ESES (Belgium/France/Nederland)
• Ondřej Dusílek, CSD Prague
• Anne Pascale Malréchauffé, Clearstream Banking SA
• Dora Matošić, SKDD
• Florentin Soliva, SIX SIS
• Maciej Trybuchowski, KDPW

ECSDA welcomes today’s announcement by the European Commission on the regulatory package for integration of the EU capital markets in line with the previously announced Savings and Investments Union (SIU) strategy.

The package represents a decisive step forward for Europe. It encompasses several layers of financial markets, including trading, clearing, settlement and asset management.

In view of the urgency to support the SIU and its essential role for further growth of the European economy, we particularly appreciate the Commission’s effort to advance this important work within a very short timeframe.

Europe needs a modern, coherent, and harmonised regulatory framework for post-trade services to support the efficiency, resilience, and competitiveness of its capital markets. CSDs contribute to these objectives by driving the modernisation and digitalisation of market ecosystems, safeguarding the integrity of securities issuance, and enhancing connectivity and cross-border platforms.

In line with our previous calls for action on EU capital markets integration, ECSDA welcomes measures that facilitate cooperation and interconnection among market infrastructures, supporting the expected liquidity growth resulting from the overall SIU programme. ECSDA also supports the further simplification of passporting procedures to strengthen the freedom of issuance.

As a follow-up to its response to the European Commission’s consultation, the Association is now carefully assessing the legislative proposals to provide input to this reform.

At ECSDA, we look forward to cooperating with the European Commission, the co-legislator, regulators, and stakeholders to provide our technical expertise to promote an integrated and globally competitive European capital market.

Anna Kulik, Secretary General, commenting on the announcement said:

“We warmly welcome today’s announcement of the SIU legislative package — a major stepping-stone towards an integrated European capital market. ECSDA stands ready to contribute its technical expertise, continue supporting digitalisation and a resilient, efficient and competitive pan-European market that serves citizens, businesses and economies alike”.

Link to the SIU package

Today, 20 October, ECSDA releases the 2025 CSD Links reports.

CSD links continue to represent the most secure and market-driven enabler of cross-border post-trade access — ensuring the highest standards of asset protection and full legal certainty for securities ownership and transfers.

In this new paper, ECSDA highlights:

• The requirements and challenges of opening and operating a link,
• The benefits for users and the alternatives to cross-border link settlement,
• Recent developments based on the latest data,
• Key policy recommendations to strengthen this efficient market linkage tool, and
• The actions needed to enhance post-trade connectivity in support of the SIU.

🔗 Discover how European CSDs are advancing their joint vision to ensure that all European securities become accessible from a single CSD account.

Link to the report

Link to the CSD links matrix