CMU: don’t get your hopes up

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CMU: don’t get your hopes up

Players of Tottenham Hotspur FC celebrate with the trophy after winning during the UEFA Europa League 2024/25 Final match between Tottenham Hotspur and Manchester United at San Mames on May 21, 2025, in Bilbao, Spain. AFP7 21/05/2025 (Europa Press via AP)

The EU had a victory this week when the ESM began clearing swaps within the euro area — but CMU still looks like a trophy out of reach

It was 10 years ago when the European Commission first launched the Capital Markets Union action plan.

Many unexpected twists and turns have occurred since then — the UK left the European Union, Donald Trump won two US presidencies, and Tottenham Hotspur scooped a major footballing trophy.

Meanwhile, progress towards CMU has been painfully slow, though there has been the occasional victory.

Most recently, the European Stability Mechanism on Monday began clearing euro interest rate swaps at Eurex, the first international and European public institution to become an IRS clearing member at a central counterparty (CCP) clearing house.

Strengthening EU clearing services was a crucial part of the second CMU package, proposed in 2022.

Encouragingly, Eurex is understood to have a pipeline of other supranational and governmental agencies in its sights — onboarding other European institutions is surely a must if the Commission expects European banks and investor counterparties to make the conversion to Frankfurt clearing.

But as it stands, London-based LCH still dominates euro interest rate swap clearing with more than 95% of the market as attempts to force such business into the euro area hits continued resistance.

Even before Brexit, the European Central Bank took legal action to try and force clearing of euro derivatives to be conducted inside the eurozone, on the grounds of mitigating systemic risk. But it lost the case in 2015.

Emboldened by Brexit, the Commission had another shot in 2020. UK CCPs were given temporary equivalence to EU standards under the European Market Infrastructure Regulation.

Three extensions later, and the deadline has been pushed back to June 2028 following lobbying from several industry groups and buy-side associations. The extensions to CCP clearing have started to feel symbolic.

If the Commission is still struggling to repatriate euro clearing — arguably one of easiest parts of the proposed CMU package — then overcoming entrenched national interests within the euro area, such as taxation, insolvency laws and banking regulation, appear to be trophies out of reach, however desirable.

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