CMCE’s advocacy and lobbying activities are directed by its membership and focused on the regulation of commodity derivative markets and participants in these markets. Within this regulation CMCE has prioritised (a) requirements for non-financial counterparties entering into over-the-counter (OTC) derivative contracts, (b) the extension of market abuse rules to spot commodity and commodity derivative transactions, (c) changes to the main regulatory regime for securities and derivatives markets, (d) regulation applicable to commodity benchmarks, (e) regulatory capital rules applicable to commercial market participants, and (f) the implication for commodities trading markets of the United Kingdom’s exit from the European Union.

CMC Europe 2025 Work Plan

In 2025, CMCE will remain focused on positioning itself as a key stakeholder in the evolving regulatory landscape following significant political changes across the EU and the UK. With a new European Parliament, a new UK Government, and increasing geopolitical tensions, we will continue to advocate for a proportionate regulatory approach that ensures the competitiveness and resilience of commodity markets while supporting broader policy goals such as the energy transition and financial stability.

We will monitor and contribute to regulatory developments in both the EU and UK, ensuring that the unique role of commodity derivatives markets is well understood by policymakers and that divergence between jurisdictions does not undermine market functioning. 

Our activities will continue to include contributions to the policy debate on global commodities regulation, informed responses to emerging geopolitical risks, and strategic engagement on regulatory files affecting market participants. 

CMCE’s priorities for 2025 include:

European Union:

  • Active monitoring and engagement on the implementation of Level 2 measures of EMIR 3.0, particularly in relation to non-financial counterparty classification
  • Active monitoring of the ongoing discussion on the EU MiFID review
  • Contributing to the development of the REMIT Implementing Regulation 
  • Monitoring developments in sustainable finance, including the Commission’s proposed omnibus regulation covering CSRD, Taxonomy, and CSDDD
  • Monitoring regulatory debates around non-bank financial intermediation (NBFI) and potential implications for commodity market participants
  • Following the upcoming ESMA report on prudential requirements for non-investment firms under the IFD/R
  • Monitoring the Commission’s review of the Carbon Border Adjustment Mechanism (CBAM) and its relevance to commodities markets

United Kingdom:

  • Contributing to the discussions on the reforms under the Wholesale Markets Review (UK MiFID – AAE qualitative/quantitative test, OMP/EMP, position management)
  • Contributing to the review of the UK EMIR framework as part of the broader Smarter Regulatory Framework (SRF)
  • Contributing to the UK Benchmarks Regulation review, in particular on commodity benchmarks
  • Monitoring the evolution of the Overseas Person Regime and its potential implications for market access
  • Monitoring UK initiatives to support the transition to a sustainable economy, including competitiveness, investment policy and pension reform under the Edinburgh Reforms