The European Association of CCP Clearing Houses (EACH) has responded to consultation on the Bank of England's fees regime for financial market infrastructure supervision 2026/2027.
More specifically, the key messages that EACH Members would like to convey are the following:
- Welcome the Bank’s efforts – EACH Members overall welcome the Bank’s efforts to manage costs and note the small reduction in the general supervision component of the CCP fee for 2026/2027
- Policy development costs – EACH does not support the inclusion of policy development costs in the annual supervisory fee regime and respectfully request their removal.
- Transparency – More transparency should be provided over expected fee trajectories, as well as on the read-across between working efficiently and prioritising within supervisory work and the proposed fees.
- Recovery period – If the Bank proceeds with recovery of rulebook costs, the recovery period should be extended further to minimise the annual impact on supervised firms, consistent with the Bank’s “have regards” obligation to consider the desirability of sustainable economic growth.
- Proportionality – We support an approach that links fee allocation to the relative systemic relevance of firms or groups of firms — such as the proposed tiered categorisation framework — as well as to the level of supervisory activity required. Nevertheless, we have some concerns regarding the considerable differences in supervisory cost burdens applied across various FMI sectors.
- Transitional arrangements for newly authorised FMIs – Although we understand the rationale for measures intended to encourage innovation and support the development of new entrants, we believe it remains important that supervisory treatment is applied consistently across firms undertaking comparable regulated activities.
Please find the full EACH response here.
