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Europe’s post‑trade landscape is changing fast, and Euronext is driving that transformation. As highlighted in the Draghi Report, divergent national systems continue to slow cross‑border activity and scale; real progress will depend on coordinated reforms that span the full post‑trade chain. 

With five central securities depositories (CSDs) already operating across Denmark, Italy, Norway, Portugal and Greece, the next major milestone for Euronext is set for September 2026. Starting then, clients trading equity and ETPs (Exchange-Traded Products) in Euronext Amsterdam, Brussels and Paris will have a choice– for the first time ever – to use either Euronext Securities or alternative CSDs for their settlement. As Euronext, we see this in line with our industrial commitment to advancing a more competitive and more consolidated post-trade infrastructure to support the growth of European capital markets, in line with the objectives of the Savings and Investment Union (SIU) promoted by the European Commission.

Historically, each Member State has been operating its own CSD, with their own operational standards, settlement practices and system architectures. This has made today’s framework a patchwork of infrastructures, imposing substantial frictions on cross‑border settlement. A major step toward addressing this fragmentation came with the launch of TARGET2‑Securities (T2S) by the European Central Bank in 2015. T2S fundamentally modernised European securities settlement by providing a unified settlement platform, removing many of the burdens associated with divergent national practices and simplifying the flow of cross‑border transactions, but its divergent use continues to hinder harmonisation.

The Market Integration Package (MIP), published by the European Commission in December 2025, seeks to build on this progress by mandating connectivity to T2S for all relevant market infrastructures. This is an important development, but connectivity alone will not fully realise the platform’s potential. For T2S to serve as a genuine European settlement layer, mandatory connection must be accompanied by mandatory usage, ensuring that transactions are settled through T2S not only in principle but in everyday practice. In parallel, the platform’s limited currency scope remains a structural constraint. Expanding T2S to support settlement in all euro and major non‑euro currencies in central‑bank money or, where this is not feasible, enabling standardised, harmonised interactions with external T2S‑approved non‑euro payment systems would be essential to transforming T2S into a truly pan‑European settlement infrastructure.

The MIP confirms the right for market participants to designate any regulated CSD for settlement. In principle, this measure can enhance competition and improve service quality in the post‑trade environment. However, its effective implementation depends on further clarification of the operational and supervisory requirements that such a regime entails. Clear and consistent conditions—potentially defined by ESMA—will be necessary to ensure that designation rights function as intended without undermining the resilience or coherence of the settlement ecosystem.

Beyond settlement reforms, the MIP proposes important changes to the rules governing access between trading venues and central counterparties (CCPs), with the aim of facilitating more interoperable clearing arrangements for equities across the EU. While Euronext agrees that enhanced connectivity may produce benefits in liquidity, efficiency and cross‑border integration, interoperability between CCPs carries inherent risks. As emphasised in the ESRB’s analysis, interoperable links introduce additional complexity and create new channels through which financial distress can spread across infrastructures unless adequate mitigation is put in place. Robust risk‑management safeguards must therefore remain the primary guiding principle in any expansion of CCP connectivity.

A core condition for safe interoperability is unified supervision. Interoperable links cannot be considered with any entity that does not fall under the same supervisory authority. Fragmented oversight creates regulatory blind spots and exposes CCPs to vulnerabilities originating outside their own jurisdiction. Supervisory unity is essential to ensure consistent risk‑management standards, coherent application of rules and effective oversight of interconnected clearing arrangements.

In addition, interoperability should remain selective and grounded in a demonstrable economic and operational rationale. The proliferation of interoperable links brings significant costs. Forced interoperability should therefore be limited to a small number of CCPs, at most one or two: where arrangements are both commercially sound and operationally resilient, and where the counterparties meet comparable prudential and supervisory standards.

Within this broader context, the Commission’s decision to exclude exchange‑traded derivatives (ETDs) from the scope of the new access rules is appropriate and necessary. ETD markets are structurally distinct from cash markets: the close alignment between trading venue and CCP is foundational to effective risk management, particularly regarding the CCP’s margining practices, default‑fund structure and overall risk model. Mandated access or forced interoperability in this segment would risk weakening well‑established safeguards and diluting the resilience of integrated ETD market structures. Preserving the exclusion of ETDs is therefore essential to maintaining both market integrity and financial stability in this critical part of the European post‑trade ecosystem.

In sum, strengthening Europe’s post‑trade architecture requires more than incremental adjustments: it demands a coherent and disciplined approach to integration, risk management and supervisory alignment. The MIP provides a meaningful foundation through T2S expansion, clearer CSD designation rules and calibrated access provisions for CCPs, but its success will ultimately depend on implementation. A more harmonised, resilient and efficient post‑trade ecosystem is within reach, provided reforms remain grounded in robust safeguards and guided by the long‑term objective of building a truly integrated European capital market.