Response to IOSCO consultation report on financial benchmarks

The Federation of European Securities Exchanges (FESE) supports IOSCO’s objective to establish a robust, overarching framework of principles for financial benchmarks. We agree with IOSCO’s differentiated approach setting broad high-level principles applicable to all benchmarks, alongside more detailed provisions for benchmarks with higher risk profiles due to their reliance on submissions or specific ownership structures. FESE emphasizes the need to distinguish between different types of benchmarks and their respective roles in the market to ensure that any regulatory framework is targeted, effective, and proportional.

We strongly supports bringing all benchmarks under the scope of civil and criminal sanctions against manipulation, and underlines the importance of sound governance, transparency, and calculation methodologies. FESE views exchanges as neutral data and index providers without the conflicts of interest seen in certain cases like LIBOR. We encourages future regulatory discussions to align with the EU’s work on market abuse (MAD/R) and to focus on enhancing independence and transparency, particularly in areas where unregulated price sources influence indices. Regulatory action must maintain a level playing field and prioritize market integrity without undermining the value of regulated venues.