Euronext Securities comment on recent National Competent Authorities’ orders regarding Open Access conditions

Euronext acknowledges it has received orders from the French AMF and the Dutch AFM and it has been informed by the Belgian FSMA of its intent to issue a similar order, in relation to the conditions initially proposed by Euronext for Central Securities Depositories (CSDs) to be confirmed as an “alternative CSD” as set out in the guidance document “Euronext Securities – Place of Settlement change guidelines” that was made available online on 1 August 2025 (the Place of Settlement Guidelines), as supplemented by the alternative settlement request forms made available on 31 October 2025. Euronext is reviewing these letters and will respond in due course to the regulators and also duly communicate with the market and other relevant stakeholders. 

The decisions and letters received from the National Competent Authorities in Belgium, France and the Netherlands do not put into question Euronext's plan to roll-out a European-wide CSD offering through Euronext Securities. It does not change Euronext’s financial targets as part of the Innovate for Growth 2027 strategic plan. It does not change the implementation, by September 2026, of the new settlement model as announced in the Place of Settlement Guidelines, under which trading members of Euronext Amsterdam, Brussels and Paris will settle in Euronext Securities Milan unless they select another CSD in compliance with the applicable regulatory framework. 

Euronext is of the view that the conditions applicable to “alternative CSDs” would allow any CSD to be ready before September 2026, to ensuring that trading members can make a timely and appropriately informed and proper choice. In fact, since the publication of such conditions by Euronext, several CSDs have applied to be confirmed as an “alternative CSD” and have confirmed to Euronext they would be ready to meet the conditions by September 2026. 

We will continue to engage in a constructive manner with all involved stakeholders, including clients, regulators and other market infrastructures, with the objective to establish a better, more competitive and more integrated European post-trade infrastructure. For the first time in decades trading members will have a true and meaningful choice in the post-trade area. 

Join us for an exclusive interview with Armanda Mago Citi’s Head of FMI Strategy and Change Management for Europe, who shares insights from over 25 years in financial services. Discover her perspective on the opportunities and challenges in European capital markets, from the transition to T+1 and digital assets to the need for greater harmonisation. Learn how her experience across front and back-office roles shapes her approach to post-trade transformation and hear about the unexpected lessons she has uncovered along the way. 

Tell us a bit about yourself and your role at Citi 

I am performing now, within Citibank Custody business, the role Head of FMI Strategy and Change Management for Europe, focused on the many anticipated changes in the European capital markets landscape over the next three to five years including the transition to T+1, SIU implementation, market infrastructure evolution, and digital assets adoption. Prior to my current role, I led Citi’s Custody business for Europe and the UK where I was responsible for business strategy, growth, and custody transformation across these geographies, including engagement with FMIs and key stakeholders. I joined Citi around 15 years ago, first in Latin America where I held a number of roles including Head of Securities Services business for the region [excluding Brazil and Mexico] and Head of Securities Services for Colombia. I moved to Europe with Citi in 2020 to lead product and service consistency across our Europe and the UK branches including Citi’s T2S markets. Prior to Citi, I spent six years as Operations and Issuer Heads at the Colombian Stock Exchange (BVC) where I led the integration project between the Colombian, Peruvian and Chilean equity markets. I now have over 25 years of experience in the financial services sector across investment banking, capital markets and the public sector and I continue to be enthused by what lies ahead. 

What do you see as the biggest opportunity and challenge that needs to be addressed in the post-trade industry? 

As multiple analysts and economists have pointed to, Europe’s capital markets have the potential to compete with the US. Europe’s capital markets have deep liquidity to attract issuers and offer attractive rates to finance the region’s economic growth while making savings more attractive and profitable to support citizens’ pensions and retirement plans. However, the landscape is complex. Multiple national laws, regulations and market practices are creating challenges like high costs and liquidity fragmentation that will need to be addressed to realize the opportunity for Europe. 

The biggest challenge and at the same time, the biggest opportunity lies in how these differences can be overcome with feasible and scalable measures. 

Some of these measures could be single rulebooks for issuance and corporate events, multimarket CSDs ensuring consistency in messaging, aligning information sources, and gaining scale to reduce costs for participants. 

What’s the most unexpected lesson you’ve learned or myth you’ve debunked by working in the financial industry? 

The most unexpected lesson I learned, while working in the financial industry was the true nature of its operational sophistication. 

My early career in capital markets, specifically in investment banking's front office, immersed me in discussions of co-location, nanosecond trade execution, algorithmic investment strategies, and the relentless pursuit of time-to-market advantages. However, transitioning to manage the back office at the exchange presented a different reality where the reliance on manual processes, paper-based workflows still existed, coupled with daily stress on end-of-day closures. While this unveiled a less glamorous, more foundational side of capital markets, it also unexpectedly ignited a deep passion for understanding and optimizing these critical, often overlooked, operational pillars. 

The European Commission’s Market Integration and Supervision Package is set to reshape how trading, post-trade and supervision operate across the EU. Positioned as a key milestone for the Savings and Investment Union, the package seeks to simplify rules and reduce long-standing fragmentation in European market infrastructure. 

To understand how the reforms could impact European capital markets and what they mean specifically for Euronext, we spoke with Dr. Jakub Michalik, Chief Policy Officer and Member of the Executive Committee at Euronext, about the strategic implications of the proposal and the opportunities it creates for deeper European market integration. 

The European Commission is positioning the Market Integration and Supervision Package as a milestone for the Savings and Investment Union. From Euronext’s perspective, which elements of the proposal are the most strategically important, and what impact would they have on the way European markets function today? 

According to Jakub Michalik, three areas of the proposal stand out from Euronext’s perspective. 

He points first to the simplification and harmonisation efforts which align closely with the Commission’s wider objective of reducing regulatory burdens by 25%. “The package contains a strong set of simplification measures,” he explains. “It introduces steps to limit duplications in regulatory reporting and establishes a single reporting hub within ESMA, which will make reporting more streamlined and more efficient.” A further source of simplification comes from the decision to rely more on regulations rather than directives, which he notes will “clean and simplify the entire regulatory framework” and reduce barriers caused by differing national transpositions, and harmonisation of supervision. 

The second major area concerns post-trade infrastructure. He welcomes the Commission’s push to enhance the use of Target2-Securities through mandatory connectivity. “T2S today already provides a strong basis for post-trade integration,” he says. “Mandatory connectivity would help create a more competitive and more integrated settlement environment in Europe.” He also highlights the proposal’s openness to new technologies, including DLT, which supports innovation in post-trade processes. 

The third element relates to market structure and liquidity, where he sees room for greater ambition. While there are some limited improvements to trading rules, he notes that there is an opportunity to further strengthen the attractiveness of European markets for capital raising. “This area is important,” he says, “because deeper liquidity and stronger market structure are essential for Europe’s competitiveness.” While Euronext addresses this with its single, proprietary trading platform Optiq®, giving clients access to Europe’s largest liquidity pool by connecting markets across Europe, a significant – and still growing – part of the European equities is traded on bilateral basis or in dark pools. “This is largely driven by unlevel regulatory playing field and policymakers and regulators need to look at this worrying trend for European markets with a remedy action”, he argues.  

The package also touches on interoperability, access rules and post-trade competition. How can Europe encourage innovation and open access while still safeguarding financial stability and avoiding fragmentation? 

Jakub Michalik notes that encouraging innovation in post-trade must go hand in hand with addressing longstanding barriers in both settlement and clearing. 

On the settlement side, he emphasises the importance of connecting all CSDs to Target2-Securities. “T2S already offers a solid basis for integration,” he says. “If all CSDs are connected, clients will be able to settle transactions in a more efficient and less fragmented environment.” He refers to the recent OXERA study on the pan-European settlement infrastructure as supporting this direction.  

The Oxera report highlights that fostering competition among CSDs can effectively address Europe’s post-trade fragmentation and help strengthen its capital markets, so long as all CSDs operate on the common settlement infrastructure, Target2-Securities. Euronext is at the forefront of this shift, broadening options for issuers, investors and intermediaries, while leading in innovation. ”Our upcoming European Offering builds directly on this momentum, providing clients with the choice to access multiple markets through a single, harmonised post-trade entry point and further reducing structural complexity across Europe” he explains. 

Turning to clearing, he acknowledges that interoperability can be a useful tool to increase competition, but stresses that it must be approached carefully. “Interoperability has potential,” he explains, “but today the European CCP landscape is quite uneven. Some CCPs are more resilient and more established in their operations than others.” 

Mandatory interoperability, he says, could introduce risk by requiring CCPs to rely on the risk management and supervision of others. “Competition should not come at the expense of financial stability,” he says, underscoring the need for a balanced approach. 

The package puts strong emphasis on cross-border supervision of trading venues, CSDs and CCPs. How will a more harmonised supervisory framework change the way pan-European infrastructures like Euronext actually operate day-to-day? 

For Jakub Michalik, increased supervisory harmonisation and a truly European approach to supervision would make a tangible difference to how groups like Euronext operate on a daily basis. 

He explains that Euronext, like other pan-European infrastructures active in trading, clearing and settlement, currently faces “various differences in supervisory approaches, supervisory culture and gold-plating across jurisdictions.” These divergences slow down the integration of activities within the Group and limit the ability to fully benefit from scale, including in areas such as intergroup outsourcing. 

A more harmonised supervisory framework, he says, would contribute to more consistent and more streamlined processes across markets. This would reflect the fact that European market infrastructures have become increasingly integrated on the private side, making the convergence of supervisory practices a natural next step. Such harmonisation also aligns with recommendations made in recent reports by Mario Draghi and Enrico Letta on strengthening Europe’s single market. 

Looking ahead, what would you say is the most important step Europe must take to build deeper liquidity pools and channel more of its private savings into productive investment, and what role do you see Euronext playing in accelerating that shift? 

Jakub Michalik emphasises that the Market Integration and Supervision Package must be seen alongside the broader set of initiatives under the Savings and Investment Union. He points to the Commission’s recent proposals aimed at strengthening retail investor participation, including frameworks for Member States to introduce savings and investment accounts and needed tax incentives to support market-based investing. Measures to increase the involvement of pension systems in equity markets, published in November, are another important component. 

“These initiatives, taken together with efforts to improve lit trading and increase addressable liquidity, can lead to higher participation in capital markets, ultimately increasing the attractivity of the European markets,” he explains. 

Euronext, he says, sees itself as an active driver of this transition. “We will continue to work with European and national authorities to make these initiatives a success, and to offer cost-efficient and simple solutions for investors.” 

Towards a stronger Savings and Investment Union  

The discussion with Jakub Michalik makes clear that the Market Integration and Supervision Package represents a decisive step towards a stronger Savings and Investment Union. Euronext welcomes the Commission’s efforts to advance more harmonised supervision, a simplified and more coherent rulebook, and deeper post-trade integration, all of which are essential to improving operational efficiency and strengthening the competitiveness of European capital markets. At the same time, as Jakub Michalik underlined, further progress on liquidity, market structure and transparency will be critical to ensure that European companies can fully benefit from deeper, more accessible capital pools. Euronext remains committed to working with policymakers and national authorities to help deliver markets that are fair, efficient and globally competitive. 

Next steps

We expect the publication of the Market Integration and Supervision Package to mark the start of an intense legislative process, whereby the European Parliament, Council of Ministers and the European Commission will analyse and debate the proposals in the coming months. We would welcome a swift conclusion of the political negotiations by early 2027, so that the European markets can benefit from the number of envisaged – and needed – improvements without unnecessary delays.