The IRSG broadly welcomes the aim of the European Commission's proposal on benchmarks to ensure benchmarks are robust and reliable. However, we feel that any regulation needs to be proportionate to the risks involved so as not to undermine the role benchmarks play in helping to enable investment and growth, as well as to ensure that any EU regulation is fully compliant with IOSCO principles to take into account that benchmarks are global. This paper focuses on three key areas: scope, proportionality and third country access.
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