FESE agrees with the main communication principles identified by ESMA in the consultation paper, including general communications informing about the disruption, regular status updates, and specific communications directly to trading members where it is not possible to communicate the status of orders from the published updates. We however caution against potential burdensome and unnecessary requirements, which would restrict trading venues’ ability to take the necessary steps to resolve a technical incident and to communicate clearly to market participants. In FESE’s view, ESMA can best promote market integrity and more consistent resiliency across EU trading venues with high-level guidance, while also allowing trading venues the flexibility necessary to resolve incidents and tailor communications in the most effective manner under the circumstances.
FESE adopted in January 2022 a framework for an industry-wide standard protocol on outages in equity markets. Since the publication of the framework and its principles (most of them similar to the ESMA proposals), FESE members have been developing and publishing playbooks on outage protocols, all of them listed in a centralised database. Frameworks for fixed income and derivatives have also been published.