BlackRock in Europe

Our EU policy publications

Viewpoints Letters and consultations Insights
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Name Topic Overview Date Link
Fractional Ownership and ETF Savings Plans Retail In this Policy Spotlight, we examine the use of fractional investing in ETF savings plans, exploring the differences in ownership models and the implications for retail investor protection. This is in response to ESMA’s proposed guidance, which aims to clarify the requirements around the use of derivatives on fractions of shares within distribution models. 16/05/2023

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European money market fund reform Money Market Funds In this ViewPoint, we take a closer look at key issues central to the European debate around increasing the resilience of MMFs. We challenge the hypothesis that the Low Volatility Net Asset Value (LVNAV) fund structure is prone to cliff edge risks and we comment on the debate around the calibration and composition of liquidity buffers. We also look beyond the events of March 2020, to the more recent experience of European MMFs, and make a number of recommendations that we believe can help further underpin MMF resilience. 7/12/2022

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Towards more transparent and resilient securities markets: a framework to support retail investor participation Securities markets In this Spotlight, we introduce a set of fundamental principles for policymakers, which we believe should form the basis for making public markets more inclusive and supportive of retail investors globally. We also make recommendations on market structure enhancements in line with these principles. 6/10/2022

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A holistic approach to bond market resilience Market structure In this Policy Spotlight, we place open-ended bond funds into the wider context of the market ecosystem, providing recommendations to enhance not only fund liquidity management, but market structure and transparency. 16/8/2022

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Regulatory Developments in Europe: 2022 Midyear Outlook CMU This ViewPoint summarises the key financial services policy developments impacting retail investors, institutional investors, and distributors in Europe. 27/7/2022

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A European perspective on managing liquidity risk in investment funds Market structure In this Spotlight, we discuss why LMTs are used, the criteria and circumstances which lead managers to choose specific LMTs over others, and the constraints posed by specific fund structures, local regulation, operational issues, and market infrastructure. 6/7/2022

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BlackRock supports consistent climate-related disclosures; urges global coordination Sustainability In this Spotlight, we express support for a global baseline of climate-related disclosure standards to enable informed investment decisions and urge regulators to work with market participants and standard setters, like the ISSB, to continue developing industry-specific guidance. 17/6/2022

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Spotlight: CCP Margin Practices - Under the Spotlight Market structure In this Policy Spotlight: CCP Margin Practices - Under the Spotlight, we review the COVID-19 market volatility and discuss our key recommendations for improving margining practices, as well as additional central clearing counterparties (CCP) resilience, recovery, and resolution recommendations. 29/3/2022

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Spotlight: Swing Pricing - Raising the Bar Market Structure In this Policy Spotlight: Swing pricing – Raising the bar, we set out our perspective on the principles that underpin swing pricing, why it is used, and the appropriate way to use it, before sharing views on best practises that should guide the swing pricing process, and offering recommendations on how to maximise its potential. 11/3/2021

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The Endgame: Benchmark Reform and Transition from IBORs Benchmark In this Policy Spotlight: Swing pricing – Raising the bar, we set out our perspective on the principles that underpin swing pricing, why it is used, and the appropriate way to use it, before sharing views on best practises that should guide the swing pricing process, and offering recommendations on how to maximise its potential. 1/6/2021

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Addendum to ‘Lessons from COVID-19: Liquidity Risk Management is Central to Open-Ended Funds’ Market structure Addendum to ‘Lessons from COVID-19: Liquidity Risk Management is Central to Open-Ended Funds' 26/1/2021

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Asset Managers of Scale give Voice to Investors and Support the Economy CMU This ViewPoint reviews how large asset managers — those that operate at scale, with a diverse client base and a long term orientation — offer value to investors, businesses, and society, by connecting capital with investments in the companies that drive the economy. We shine a light on the role that asset managers play as stewards of investments, encouraging portfolio companies to deliver long-term value through sound governance. 31/12/2020

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Lessons from COVID-19: Market Structure Underlies Interconnectedness of the Financial Market Ecosystem Market structure In this ViewPoint, we discuss the evolving market ecosystem and examine how market infrastructure contributed to the short lived but intense liquidity crisis of March 2020. 23/11/2020

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Lessons from COVID-19: Liquidity Risk Management is Central to Open-Ended Funds Market structure In this ViewPoint, we examine the effect of stressed markets on open-ended funds, and bond funds in particular. We then review the liquidity risk management tools available to asset managers, and how they were deployed during March 2020. Finally, we offer recommendations to increase the effectiveness of liquidity risk management tools, thereby enhancing the resilience of mutual funds. 5/11/2020

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Swing pricing: The dilution effects of investor trading activity on mutual funds Market structure This paper considers processes that provide protection to existing mutual fund investors from the negative ‘dilution impact’ that occurs when a fund invests or disinvests in securities as a result of investor activity. In this paper, we discuss how our single‑priced UCITS and UCI funds address the issue, through our development of the technique known as swing pricing. 31/10/2020

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Lessons from COVID-19: Operational Risk and Resilience Market structure In this ViewPoint, we analyze operational challenges faced by the asset management industry during COVID-19, explore how the industry has responded to these challenges, and outline a series of recommendations to further bolster operational resilience. 22/10/2020

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Lessons from COVID-19: Overview of Financial Stability and Non-Bank Financial Institutions Financial Stability This ViewPoint summarizes key takeaways from our series of ViewPoints on "Lessons from COVID-19", considers the implications of the COVID-19 crisis across capital markets, and outlines policy recommendations. 30/9/2020

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Deck - Lessons from COVID-19: Overview of Financial Stability and Non-Bank Financial Institutions Financial Stability This deck is a companion to our ViewPoint titled "Lessons from COVID-19: Overview of Financial Stability and Non-Bank Financial Institutions". 30/9/2020

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Lessons from COVID-19: ETFs as a Source of Stability Market structure In this ViewPoint, we explore how ETFs were a source of stability during the first part of 2020 amidst unprecedented market volatility by providing price transparency and liquidity. While ETFs generally functioned well during the COVID-19 crisis, we also offer recommendations for how the ETF ecosystem can be further strengthened. 17/7/2020

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Lessons from COVID-19: The Experience of European MMFs in Short-Term Markets Financial Stability In this ViewPoint, we make a holistic assessment of European short-term markets during the March market turmoil. We identify three key components of the short-term market ecosystem: market structure, banks as intermediaries, and money market funds. In each pillar, we examine the challenges that arose and make recommendations for improvements to enhance financial stability. 17/7/2020

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Lessons from COVID-19: Fixed Income Index Rebalancing Market structure In this Policy Spotlight, we discuss how index providers’ decisions to delay fixed income index rebalancing during March 2020 helped to preserve market liquidity, avoid central bank interventions from being undermined, and prevent unnecessarily large transaction costs for end-investors. 17/7/2020

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BlackRock’s Guide to LIBOR Transition Benchmark This ViewPoint focuses on providing a status update on LIBOR transition, information on upcoming milestones, BlackRock’s transition planning, and other information to serve as a reference and guide for clients, industry participants, and stakeholders during the next critical steps of transition from LIBOR. 4/29/2020

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Securities Lending Viewed through the Sustainability Lens Sustainability In this Spotlight, we explore the intersection of securities lending with short selling and investment stewardship through the lens of sustainable investing. 28/4/2020

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Europe’s listed companies: their governance, shareholders and votes cast CMU In this ViewPoint, we analyze the ownership of companies in the MSCI Europe index and examined the proxy voting of their 30 largest institutional shareholders. 21/2/2020

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Towards a Common Language for Sustainable Investing Sustainability In this ViewPoint, we review current global regulatory efforts to develop and implement more standardized terminology for sustainable investing, and we outline recommendations to increase clarity around (i) sustainable investment product naming conventions, (ii) corporate issuer disclosures, and (iii) sustainable economic activities. 14/1/2020

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The Decade of Financial Regulatory Reform: 2009 to 2019 Other In this ViewPoint, we examine financial regulatory reforms over the past decade, with a focus on the asset management sector. In addition, we look ahead and identify several areas that merit additional study from a systemic risk perspective. 5/1/2020

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Putting the capital in the European Capital Markets Union CMU In this ViewPoint, we set out a vision for a recast of the European Capital Markets Union agenda and put forward our recommendations for building deeper, better-connected capital markets in Europe. 3/10/2019

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LIBOR: The Next Chapter Benchmark Updated to reflect developments in the last year, this ViewPoint considers the future of LIBOR and alternative reference rates. 8/4/2019

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Mark-to-market structure: An end-investor perspective on the evolution of developed equity markets Market structure This ViewPoint considers the key trends of technological advances and new regulations that have driven changes in equity market structure in recent years. With these in mind, we put forward principles that we believe should inform future regulation and offer a series of recommendations for US and EU market structure. 22/2/2019

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Disclosing Transaction Costs - The need for a common framework Retail In this ViewPoint, we consider the regulatory landscape that drives the provision of conflicting standards for cost disclosure. After setting out how costs and charges are incurred in investment portfolios, we compare the advantages and drawbacks of the commonly used Spread and Slippage methodologies, seeking to inform a common disclosure standard. 17/8/2018

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Addressing Market Liquidity: A Broader Perspective on Today’s Euro Corporate Bond Market CMU The dialogue on bond market liquidity has largely focused on a few key trends: (i) the decline in broker-dealer inventories, (ii) the decline in bond turnover (trading volume as currently measured divided by outstanding debt), (iii) the increase in corporate bond issuance, and (iv) the growth of bond mutual funds. While the data cited are factually accurate, these isolated data points do not present a complete picture of bond market participants or innovations that are supplementing traditional means of obtaining market liquidity. This ViewPoint is intended to inform discussions about bond market liquidity by integrating data we have known about for a long time (e.g., bond ownership by pensions and insurers) with newer data that highlights structural changes to bond market liquidity. Based on our synthesis of the new data with the old, we make a number of observations to provide a more comprehensive foundation for the dialogue on bond market liquidity. 4/11/2016

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The Changing Face of European Distribution: A Better Financial Future for Savers? Retirement This ViewPoint outlines the expectations of savers to address their long-term financial needs and the current regulatory changes affecting distribution and advice in Europe. 7/4/2014

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Securitisation - A Tool For European Growth CMU Policymakers are keen to stimulate securitisation markets in the European Union in order to increase the range of financing opportunities available. This ViewPoint seeks to provide a brief overview of securitisation and highlights its benefits for companies, investors, banks and the economy. It also identifies some of the misuses of securitised instruments and the degree to which industry practice and regulation have addressed concerns and recommends guiding principles to stimulate the re-emergence of healthy securitisations. 28/3/2014

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The EU Financial Transaction Tax: A Tax on Savers Tax Recent media reports have focused on the legality of certain aspects of the Financial Transaction Tax and led some to believe that the proposal is now dead. The idea continues to attract strong support from some proponent countries and the European Commission. In this ViewPoint, we explain why and how the FTT proposal will be very damaging to end-investors, in particular long-term savers and pensioners, and express our strong objection to the FTT on our clients' behalf. 28/6/2013

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Best Practices for Better Benchmarks: Recommendations for Financial Benchmark Reform Benchmark Financial benchmarks are under review by multiple regulators around the world as a result of the allegations of manipulation of LIBOR that have surfaced. We commend the efforts to learn more about financial benchmarks, as they are used by a wide range of investors and market participants. As the discussions proceed, however, we caution regulators to carefully evaluate what types of reforms may benefit investors and which may impose unintended harm. This paper outlines the key differences between rate benchmarks and market benchmarks (commonly called market indices), and advocates prudent reform that is in the best interests of investors and financial markets. 13/3/2013

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Money Market Funds: A Path Forward Financial Stability  Policymakers globally continue to grapple with the regulation of Money Market Funds in the wake of the 2007/2008 financial crisis. A seemingly simple product has challenged some of the best regulatory, industry and academic minds, and consensus on a proposal for additional reforms still appears to be elusive. We at BlackRock have been deeply engaged in these discussions and - like others - have worked on numerous proposals for reform based on the lessons learned in 2008. In this paper, we propose a path forward that takes into account the various concerns and objections that have been raised in past discussions. 26/9/2012

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Regulatory Reform of European Debt Markets - Balancing the costs and benefits Market structure This ViewPoint considers if European corporate debt markets can withstand the challenges they currently face from the current macro-economic conditions coupled with an intense period of regulatory change. The Review of the Markets in Financial Instruments Directive (MiFID) in Europe could herald an unprecedented shift in how fixed income market makers would be obliged to report to regulators and to the market. In this paper, we focus on whether the current reform of European fixed income market structure would bring added value for end-investors or if the costs of proposed reforms exceed their potential benefits. In conclusion, we provide recommendations to address the public policy intentions behind the reforms whilst protecting the fixed income markets from increased liquidity pressure. 25/9/2012

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LIBOR - Where Do We Go From Here? Benchmark The recent issues surrounding LIBOR highlight two key, yet separate issues: alleged manipulation of LIBOR during the precrisis period, and the alleged underreporting of LIBOR due to the stigma issues at the height of the 2008 credit crisis. The conflation of these two distinct issues have cast doubt on the credibility of the LIBOR rate setting process. Lost in the noise is the importance of reforming this process to regain the confidence of market participants. This paper highlights the need for industry-wide benchmarks and makes specific suggestions for reforms of the LIBOR rate setting process to help it regain credibility. 30/7/2012

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Central Clearing in Europe - Implications for Pension Plans Market structure This ViewPoint gives a detailed explanation of central clearing requirements for OTC derivatives in the European Union and shows the implications for European pension plans. 8/7/2012

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Credit Valuation Adjustment in Europe - Implications for Pension Plans Retirement This ViewPoint gives a detailed explanation of the Credit Valuation Adjustment risk charge under the Capital Requirement Directive IV (CRD IV) and shows the implications for European pension plans. 8/7/2012

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Money Market Funds: The Debate Continues - Mar 2012 Financial Stability Money market funds have been a topic of discussion - and often vehement disagreement - among regulators and market participants since the 2008 financial crisis and historic "breaking of the buck" by the Reserve Primary Fund. At this juncture, given regulators' stated intention to move forward with structural reform, it is important to identify a proposal that preserves MMFs and is acceptable to as many industry participants as possible. The model expected to be put forth by the SEC provides the option of either: i) a stable-NAV MMF with capital buffers plus redemption restrictions or ii) a floating-NAV MMF. In this paper, we examine the merits and implications of these ideas. We also consider the case for whether regulators have already done enough. 2/3/2012

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ViewPoint - Restoring Investor Confidence Retail Much has happened over the past decade to reshape the economic landscape. The greater sophistication and more complex structure of financial markets, rapid technological developments, and the increase in third-party intermediated distribution models have enhanced the opportunities available to investors. In this ViewPoint, we look at how to rebuild investor confidence in the light of European proposals to update consumer regulation of financial services. We consider how to preserve investor choice and make specific recommendations to improve the regulation of product providers and distributors. 4/1/2012

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ETFs: A Call for Greater Transparency and Consistent Regulation - Oct 2011 Market structure In this ViewPoint, we provide background on the history and structure of ETFs, summarize recent concerns that have been raised by regulators, and recommend five reforms that would improve the marketplace for ETFs. We explicitly support uniform standards on labeling, transparency, disclosure, and reporting that would reduce systemic risk, improve investor protection, and help ensure that investors understand precisely the risks and attributes of the products that they are purchasing. 14/10/2011

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Money Market Funds: Potential Structural Solutions - Aug 2011 Financial Stability  Proposals related to further structural reform of money market funds remain highly topical today. In this ViewPoint, we review the objectives and constraints surrounding additional reform, focusing specifically on capital solutions. As change is considered, care must be taken to ensure that the reforms, both individually and collectively, achieve the objective of protecting investors without inadvertently destabilizing financial markets. 15/8/2011

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Equity Market Trading in Europe: The Case for Refinement Over Revolution Retail Equity Market Trading in Europe: The Case for Refinement Over Revolution 27/6/2011

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Alternative Investment Fund Managers Directive (AIFMD): An Overview and Analysis CMU The AIFMD is one of the most radical, politicized, and controversial directives reshaping fund management and marketing regulation in the EU. The impetus behind the Directive was to prevent hedge funds posing risk to European financial stability, though the scope is far wider than just hedge funds and private equity. Although the final text of the AIFMD is far better than the original Commission proposal, we are continuing to engage at Level 2 (implementation measures) with trade associations and regulators on behalf of our clients. Investors should continue to have access to best-in-class funds wherever such funds are domiciled or managed. 8/5/2011

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UCITS IV Key Investor Information Document: The Challenge of Providing Clear Product Disclosure CMU In this ViewPoint, "UCITS IV Key Investor Information Document: The Challenge of Providing Clear Product Disclosure" we provide background on the Key Investor Information Document (KIID), which will replace the existing simplified prospectus. Following the financial crisis, there was a strong drive to provide clearer product information to investors. The KIID identifies the key elements of a fund, helping investors to understand the nature and risks of the fund in order to make more informed investment decisions. 3/4/2011

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OTC Derivative Market Reforms: An Investor Perspective Market structure In the wake of the financial crisis, legislators and regulators around the world have initiated a variety of proposals aimed at reducing the systemic risks posed by OTC derivatives. In this ViewPoint, "OTC Derivative Market Reforms: An Investor Perspective," we summarize current proposals, offer our views on their effectiveness, and highlight issues that should be addressed before new rules take effect. 1/11/2010

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The Rise of UCITS III CMU In this ViewPoint, "The Rise of UCITS III," we examine recent regulatory changes in Europe that have allowed regulated mutual fund structures to deploy enhanced investment powers, enabling leverage, paving the way for the use of derivatives, and making absolute return products available to the retail investor. 1/9/2010

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Reducing Risk in the Global Financial System: A Proposal for OTC Derivative Markets Reform Financial Stability While we support efforts to improve the regulation and oversight of the OTC derivatives market, we want to ensure that new restrictions on these important financial instruments address existing risk concerns without creating unintended negative consequences. 1/2/2010

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Name Topic Date Link
EC - Targeted consultation on the implementation of the Sustainable Finance Disclosures Regulation (SFDR) Sustainability 15/12/2023

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Irish Department of Finance - Funds Sector 2030 Review: A Framework for Open, Resilient & Developing Markets Funds 15/9/2023

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ESMA Consultation on Guidelines for the use of ESG in fund names Sustainability 20/2/2023

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ISSB Response to Exposure Draft ED/2022/S1 on General Requirements for Disclosure of Sustainability-related Financial Information Sustainability 1/8/2022

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ISSB Response to Exposure Draft ED/2022/S2 on Climate-related Disclosures Sustainability 7/8/2022

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EFRAG Consultation on European Sustainability Reporting Standards Sustainability 1/8/2022

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Proposal for a Directive on Corporate Sustainability Due Diligence Sustainability 8/7/2022

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IOSCO ETF Good Practices & Corporate Bond Market Consultations Market structure 8/7/2022

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EC Consultation on the functioning of the Money Market Fund Regulation Financial Stability  13/5/2022

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EC Consultation on Options to Enhance the Suitability and Appropriateness Assessments Retail 21/3/2022

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EC Consultation on Strenghtening the Quality of Corporate Reporting and its Enforcement   4/2/2022

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BCBS-CPMI-IOSCO - Consultative Report on Margining Practices Market structure 26/1/2022

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ESMA - Call for Advice on certain aspects relating to retail investor protection Retail 30/12/2021

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IOSCO - Consultation Report on Sustainability-related Disclosures for Asset Managers, Greenwashing and other Investor Protection Concerns Sustainability 18/8/2021

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FSB - Consultation Report on Policy Proposals to Enhance Money Market Fund Resilience Financial Stability 17/8/2021

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EC - Consultation on a Retail Investment Strategy for Europe Retail 3/8/2021

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ESMA - Consultation Paper on the Algorithm Trading Market structure 12/3/2021

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EC - Consultation on Sustainable Corporate Governance Stewardship 17/2/2021

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ESMA - Consultation on Draft Guidelines on Marketing Communication Retail 8/2/2021

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EC - Consultation on the Review of Regulation on Improving Securities Settlement in the European Union and on Central Securities Depositories Market structure 2/2/2021

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EC - Public Consultation on the Review of the European Long-term Investment Funds (ELTIF) Regulatory Framework CMU 2/2/2021

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EC - Consultation on the Review of the Alternative Investment Fund Managers Directive (AIFMD) CMU 29/1/2021

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ESMA - Consultation Paper on Guidelines on the MiFID II/MiFIR Obligations on Market data Market structure 11/1/2021

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IFRS Foundation - Consultation Paper on Sustainability Reporting Sustainability 30/12/2020

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EC - Consultation on Draft Delegated Acts Developing the EU Taxonomy Sustainability 12/18/2020

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IOSCO - Consultation report on the use of artificial intelligence and machine learning by market intermediaries and asset managers Technology 26/10/2020

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ESMA - Consultation on Guidelines on Outsourcing to Cloud Service Providers Technology 1/9/2020

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Multi-Firm Response to FSB Consultation on CCP Resolution Market structure 31/7/2020

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ESMA - Consultation on Draft Implementing Technical Standards under the Regulation on Cross-border Distribution of Funds Retail 30/6/2020

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EC - Consultation on a new Digital Finance Strategy for Europe / FinTech Action Plan Technology 26/7/2020

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EC - Consultation on Review of the MiFID II / MiFIR regulatory framework Market structure 18/5/2020

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ESAs - Joint Consultation Paper response concerning amendments to the PRIIPs KID Retail 13/1/2020

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ESMA - Consultation on Performance Fees in UCITS CMU 31/10/2019

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ESMA - Call for Evidence on the Impact of the Inducements and Costs and Charges Disclosure Requirements under MiFID II Retail 6/9/2019

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ESMA - Consultation on the Development in Prices for Pre- and Post-Trade Data and on the Consolidated Tape for Equity Instruments CMU 6/9/2019

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ESMA - Survey on Collection of Evidence on Undue Short-term Pressure from the Financial Sector on Corporations Market structure 29/7/2019

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EC - Comments on JRC Technical Report on EU Ecolabel Draft Criteria Proposal for the Product Scope and Ecological Criteria Sustainability 6/5/2019

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ESMA - Consultation on Guidelines on Liquidity Stress Testing in UCITS and AIFs CMU 29/3/2019

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BMF - Consultation on the implementation of MiFID II and MiFIR Retail 15/3/2019

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ESMA - Consultation on Integrating Sustainability Risks and Factors in MiFID II Sustainability 19/2/2019

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ESMA - Consultation on Integrating Sustainability Risks and Factors in the UCITS Directive and AIFMD Sustainability 19/2/2019

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ECB - Consultation on Determining an ESTER-based Term Structure Methodology as a Fallback in EURIBOR-linked Contracts Benchmark 1/2/2019

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ECB - Report by the Working Group on Euro Risk-free Rates on the Transition from EONIA to ESTER Benchmark 1/2/2019

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IOSCO - Public Comment on IOSCO Report on Leverage Market structure 1/2/2019

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FSB - Discussion Paper: Resources to Support CCP Resolution and the Treatment of CCP Equity in Resolution Market structure 1/2/2019

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DCGK - Proposed Changes for Amendments to the German Corporate Governance Code Stewardship 30/1/2019

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Remarks by Barbara Novick at the Greenwich Roundtable Panel Discussion on ESG: Path to Prosperity or Philanthropic Confusion Sustainability 17/1/2019

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ESMA - Call for Evidence: Periodic Auctions for Equity Instruments Market structure 20/1/2019

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ESAs - Joint Consultation Paper concerning amendments to the PRIIPs KID Retail 6/12/2018

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ESMA - Consultation on Draft Guidelines on Stress Scenarios under the MMF Regulation Market structure 30/11/2018

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Remarks by Barbara Novick at the World Economic Forum Sustainable Development Impact Summit Sustainability 16/10/2018

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CBI - Consultation on Amendments to the Central Bank UCITS Regulations Market structure 22/6/2018

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Name Topic Date Link
Ideas Exchange – Squaring the circle: The transition to net zero in an era of inflationary pressure Sustainability 14/06/2022

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Ideas Exchange – EU Fiscal Rules: where to from here? Macroeconomics 21/12/2022

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Ideas Exchange - How resilient is the food supply in times of crisis? Sustainability 20/04/2023

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