ESMA held a consultation earlier this year on technical standards for position limits in commodity derivatives markets. AMAFI said in its feedback that, overall, ESMA’s proposals were appropriate for the stated goals of the MiFID II Quick Fix package, namely to simplify the position limit regime and introduce a system that will better support the development of new, less liquid contracts (AMAFI / 21-45).

But AMAFI also voiced scepticism about some of the proposals for technical standards on position management controls. It argued that the proposals, including one to introduce the notion of “close links” to the monitoring of participant positions, impose new obligations that are incompatible with the business of trading venues dealing in commodity derivatives.