EBF Response to ESMA’s Call for Evidence on the Market Structure of European Equity Markets

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Brussels, 7 July 2026 – The European Banking Federation (EBF) responded to the European Securities and Markets Authority’s (ESMA) Call for Evidence on the market structure of European equity markets, contributing to the ongoing policy discussion on the future development of Europe’s equity trading landscape.

In its response, the EBF highlights that vibrant and attractive secondary markets are best served by a trading landscape where investors can choose to execute trades across different venues and access liquidity through different channels, including multilateral and bilateral trading.

The EBF recognises the central role of primary trading venues, in particular central limit order books (CLOBs), in supporting capital markets, and generally agrees with market trends identified by ESMA, including the migration of on-book trading activity from lit continuous order books towards closing auctions and frequent batch auctions.

The response also underlines the important role played by Systematic Internalisers (SIs) within the European market ecosystem. Unlike multilateral trading venues, SIs operate bilaterally, using their own balance sheet and risk capacity to offer clients tailored execution and liquidity solutions. The EBF considers the growing importance of SI trading to be a market-driven evolution, reflecting rising costs, evolving execution needs and adaptation to market dynamics, rather than evidence of a structural regulatory problem. EBF highlights that any case of internalised activity falling outside the scope of at-own-risk, bilateral systematic internalisation should be addressed through the enforcement of the existing framework rather than through additional legislation.

At the same time, the EBF recognises that excessive market fragmentation can create operational and connectivity cost challenges for smaller and medium-sized intermediaries. Meeting best execution obligations increasingly requires access to multiple trading venues and liquidity pools, resulting in higher costs for connectivity, market data, trading and market monitoring.

The EBF also highlights the importance of the forthcoming Consolidated Tape as a key initiative to improve market transparency and provide market participants with a more comprehensive view of trading activity across European equity markets. Together with measures addressing structural barriers to competition, it can contribute to a more integrated, competitive and efficient European market.

Finally, the EBF considers that any significant changes to the current market structure should be supported by robust evidence. In particular, the EBF believes that more compelling evidence is needed to demonstrate any deterioration in price formation, taking into account the full range of factors contributing to price discovery, as well as any link between developments in secondary market structure and the attractiveness of EU markets for listings.

In the context of the ongoing policy debate on the Market Infrastructure and Supervision Package (MISP), therefore, EBF finds that the Commission’s initial view to suggest improvements to the Consolidated Tape regime, especially from a pre-trade transparency perspective, rather than to introduce radical change to the current equity market structure, constitutes a more balanced policy option, grounded in evidence corroborated by ESMA’s Call for Evidence.

For more information:

Jacopo Borgognone, Head of Capital Markets – j.borgognone@ebf.eu

Emanuela Manenti, Policy Adviser of Capital Markets – e.manenti@ebf.eu

About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.