Revision of the Central Securities Depositories Regulation

Briefing 23-09-2022

The IA provides a convincing justification for revising the CSD Regulation. The analysis, both qualitative and quantitative, is based on the targeted evaluation of the existing CSD Regulation, targeted stakeholder consultation and various data sources (ESMA). However, the IA would have benefited from a more detailed description of the problems, the policy options, and the stakeholder consultation, including the consultation results. Moreover, views of stakeholder groups on the policy options and support for the preferred package of options are not indicated. The IA transparently explains the uncertainties and limitations in the analysis, such as the effect of the lack of data concerning third-country CSDs in the EU, and difficulties in quantifying the impacts of policy options in the area of banking services. When analysing the impacts on stakeholder groups, the IA does not differentiate in terms of company size, even though one objective of this REFIT initiative is to reduce the burden on small companies.