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European secondary equity market structure has emerged as a central focus in negotiations around the EU’ s Market Integration and Supervision Package( MISP)- a landmark set of reforms designed to improve the competitiveness of EU capital markets. Alongside this, ESMA ' s recent‘ call for evidence’ on European equity market structure offered a timely opportunity to assess the current framework and inform how best to move it forward under MISP. Cboe Europe welcomed the opportunity to contribute to this process, bringing our unique perspective as the region ' s largest equities exchange by value traded, and a deep commitment to a competitive, investor-focused and pan-European market structure.
Our core message is simple: the secondary market is performing well amid record levels of investor interest, and the competitive framework built under Mifid I and Mifid II is delivering. MISP should build on – not disrupt- this positive momentum. Whilst there is room to strengthen EU capital markets, particularly when it comes to the IPO and post-trade ecosystems, wholesale reform of secondary markets isn’ t necessary. Instead, targeted refinements would be most effective.
ESMA paints positive picture of European markets The‘ call for evidence’ was underpinned by ESMA ' s detailed analysis of transaction reporting data from Q1 2022 to Q4 2025( see table).
The key takeaway is one of strength: on-book trading is high and stable, with pre-trade transparent venues – and Central Limit Order Books( CLOBs) in particular- the main sources
Less is more for EU’ s equity market structure reforms
Europe’ s secondary equity markets don’ t need a sweeping overhaul, instead incremental reform can boost choice and competition, improve integration and investor outcomes across Europe, writes Alex Dalley, head of European equities at Cboe.
of liquidity and strong centres of price formation. This is not a market in crisis, and stands in sharp contrast to the exaggerated- albeit persistent- claims from certain vested interests that dark and off-book mechanisms have grown excessively at the expense of lit markets. What we are seeing is a redistribution of activity across a broader range of venues and mechanisms that, in most cases, deliver materially better outcomes for investors.
Competition and diversity of trading mechanisms is working- Don ' t reverse it ESMA ' s analysis- reinforced by recent periods of elevated market activity- shows that competition in equity trading is working well, and investors have never had it better in terms of execution quality, trading costs, and choice of venue. The growth of alternative mechanisms reflects evolving investor needs and increasingly sophisticated execution strategies, not any fundamental weakness in European market structure.
A well-functioning European equity market requires a range of mechanisms that serve the different needs participants. CLOBs provide continuous liquidity and price discovery for urgent order flow. Closing auctions aggregate end-of-day demand at a single reference price. Frequent Batch Auctions( FBAs) provide a transparent, on-venue mechanism for investors to find counterparties without being disadvantaged by latency. SIs offer differentiated liquidity via capital commitment. Each has a role; none is a substitute for the others.
Any measures restricting the way institutional equity trading business can execute within the
36 // TheTRADE // Q2 2026