This position paper sets out the ABBL’s views on the European Commission’s Market Integration and Supervision Package (MISP), a key initiative aimed at strengthening the integration, resilience and competitiveness of EU capital markets. The document supports the objective of deeper market integration while advocating for a convergence-first approach to supervision, rather than broad centralisation at EU level. It highlights key concerns related to the potential expansion of ESMA’s powers, the introduction of a depositary passport, and the supervision of crypto-asset service providers (CASPs). The paper also provides detailed recommendations on the evolution of the DLT Pilot Regime, including scaling, settlement frameworks and interoperability, to support innovation while preserving financial stability and investor protection. Overall, the ABBL calls for a balanced, proportionate and evidence-based regulatory framework that reinforces cross-border activity without undermining established financial ecosystems such as Luxembourg.
