CMCE’s advocacy and lobbying activities are directed by its membership and focused on the regulation of commodity derivative markets and participants in these markets. Within this regulation CMCE has prioritised (a) requirements for non-financial counterparties entering into over-the-counter (OTC) derivative contracts, (b) the extension of market abuse rules to spot commodity and commodity derivative transactions, (c) changes to the main regulatory regime for securities and derivatives markets, (d) regulation applicable to commodity benchmarks, (e) regulatory capital rules applicable to commercial market participants, and (f) the implication for commodities trading markets of the United Kingdom’s exit from the European Union.

CMC Europe 2026 Work Plan

In 2026, CMCE will operate in a markedly different phase of the regulatory cycle. After several years of intensive rule-making and policy debate, both the EU and the UK are moving decisively into implementation, supervision and enforcement. For commodity market participants, this transition materially raises regulatory risk. The focus is no longer on what the rules say on paper, but on how they are interpreted and applied by authorities with expanding mandates and data capabilities.

Within this environment, CMCE will serve as an important link between regulatory intent and market functioning, with a strong focus on the practical application and supervisory impact of recently adopted rules. This will involve sustained engagement with supervisors, early identification of potential unintended consequences, and coordinated industry input where supervisory approaches risk affecting market liquidity, risk management practices or cross border activity.

Regulatory divergence will also become a more prominent consideration in 2026. In the EU, supervisory convergence and centralisation continue to advance across EMIR, MiFID and energy market oversight. At the same time, the UK is progressing its post Brexit financial services reforms under the Smarter Regulatory Framework, with implications for EMIR, MiFID, benchmarks and the commodity derivatives regime. For globally active commodity firms, these parallel developments add complexity and increase the cost of compliance. CMCE will focus on identifying areas where divergence may become challenging and engaging early with policymakers to support continuity and avoid unnecessary market disruption. 

CMCE’s activities in 2026 will be more tightly focused on supervisory dialogue and technical implementation issues, underpinned by real-time intelligence sharing. Building on established relationships with the European Commission, ACER, ESMA, the FCA and HM Treasury, CMCE will continue to advocate for workable thresholds and commodity specific treatments across EU and UK frameworks, while providing members with up to date insight into geopolitical, energy and market developments that influence regulatory priorities.

CMCE’s priorities for 2026 include:

European Union:

  • Monitoring and engagement following the European Commission’s report on the functioning of the commodity derivatives framework under MiFID, including any follow-up linked to the Gas Market Task Force.
  • Close engagement with ACER on the entry into force and application of the REMIT Implementing Regulation, including reporting obligations, registration requirements and data oversight.
  • Monitoring developments related to EU energy policy measures and initiatives affecting energy and commodity markets.
  • Following the EU’s simplification agenda and its potential implications for existing legislation relevant to commodity market participants.
  • Ongoing engagement on the implementation and supervisory application of EMIR 3.0, including CCP participation requirements and revised clearing thresholds, and their implications for commodity market participants.

United Kingdom:

  • Leading engagement on the reform of the UK Benchmarks Regulation, particularly in relation to commodity benchmarks and the future treatment of Annex II.
  • Monitoring developments under the UK EMIR framework, including clearing thresholds and exemptions relevant to commodity market participants.
  • Monitoring the development and implementation of the Overseas Recognition Regime and its implications for market access and cross-border activity.
  • Following UK regulatory and supervisory priorities linked to competitiveness, market oversight and data.