Key dates
- 12 November 2025
- - AFM issues an instruction to Euronext Amsterdam for breach of CSDR Article 53(1) open access rules and sets a period for remediation
- 13 May 2026
- - AFM publishes the instruction decision after it becomes irrevocable and confirms that Euronext has remediated by withdrawing the restrictive conditions and confirming continued and new access for CSDs
Suggested considerations
- Trading venues must review settlement models, CSD linkage arrangements and related policies to ensure that all conditions for CSD access to transaction feeds are non‑discriminatory, transparent, and fully aligned with Article 53(1) of CSDR.
- Compliance and legal teams must identify and remove any contractual or operational provisions that directly or indirectly favour a linked or in‑house CSD over independent or alternative CSDs in terms of access to transaction feeds.
- Trading venues must implement internal governance and change‑management controls to ensure that future settlement model changes, including the introduction of a preferred CSD, are subject to ex‑ante compliance review against CSDR open access obligations.
- Market infrastructure firms must establish documented criteria and procedures for handling CSD access requests, ensuring these criteria are objective, transparent, and applied consistently to linked and non‑linked CSDs.
- Compliance functions should conduct periodic audits of access arrangements, transaction feed connectivity, and any associated fees or technical requirements to confirm that no indirect barriers to CSD access exist.
What changed
- - Trading venues subject to CSDR must ensure that access for central securities depositories to transaction feeds is provided on a non‑discriminatory and transparent basis as required by Article...
- Conditions or criteria attached to the designation of an alternative CSD (other than a venue’s preferred or “linked” CSD) that have the effect of limiting access to transaction feeds are treated as a...
- AFM has clarified, through enforcement, that settlement model changes and associated contractual or operational conditions are within the scope of supervisory scrutiny for compliance with CSDR open...
- Euronext has withdrawn three announced conditions that restricted access for certain CSDs and has confirmed continued access for CSDs with existing connectivity to its transaction feeds.
- Euronext has also confirmed access for other CSDs that requested access to act as alternative CSDs, establishing a practical expectation that trading venues respond positively to reasonable access...
Compliance impact
Non‑compliance with CSDR open access obligations can lead to formal instructions, ongoing supervisory monitoring, reputational damage through public enforcement decisions, and potentially further sanctions where breaches are not timely remediated. Given the centrality of CSD access to post‑trade infrastructure, persistent breaches may also trigger broader scrutiny of governance, conflicts of interest, and competition concerns.