FSMA Decision on Supplementary Deferral of Publication for Medium-Sized Belgian Sovereign Bond Transactions

Congresstraat / rue du Congrès 12 -14 1000 Brussels / www.fsma.be FSMA_2026_12 of 28/04/2026 Decision on supplementary deferral of publication of the volume of medium -sized transactions in Belgian sovereign bonds - Article 11 (3) of MiFIR Scope: The FSMA’s decision of 22 April 2026 taken on the basis of Article 11 (3) of Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments (hereafter ‘MiFIR’), as set out in this document, applies to transactions in Belgian sovereign bonds and, specifically, to those classified within Group 1, for transactions in Category 1 (medium-sized, in liquid instruments) as defined in Table 2.6 of Annex III of Commission Delegated Regulation (EU) 2017/583 supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council on markets in financial instruments with regard to regulatory technical standards on transparency requirements for trading venues and investment firms in respect of bonds, structured finance products, emission allowances and derivatives (hereafter ‘Delegated Regulation (EU) 2017/583’). Summary/Objectives: On 22 April 2026, the FSMA decided, in application of Article 11 (3) of MiFIR, to authorize a supplementary deferral of the publication of the volume of transactions of a medium size in Belgian sovereign bonds. This supplementary deferral is in addition to the deferral of the publication of details of transactions in sovereign bonds set out in Delegated Regulation (EU) 2017/583. Specifically, a supplementary deferral of publication is granted until the end of the trading day, for the volume of Belgian sovereign bonds classified within Group 1, for transactions in Category 1 (medium-sized, in liquid instruments) instead of the 15 minutes provided for in Delegated Regulation (EU) 2017/583. This decision enters into force on 4 May 2026. Communication

2/3 / FSMA_2026_12 of 28/04/2026 / FSMA MiFIR lays down a framework for post-trade transparency in financial instruments, including sovereign bonds, with the aim of ensuring timely and appropriate disclosure of trade data, preventing liquidity providers from being exposed to undue risks and upholding market integrity and the orderly functioning of financial markets. In accordance with Article 11 (3) of MiFIR, the FSMA may authorize supplementary deferral measures for post-trade transparency requirements in respect of sovereign bonds issued in Belgium, where such measures are necessary in order to take account of the specific characteristics of the market for sovereign bonds. These supplementary deferral measures can contribute to ensuring appropriate protection of market liquidity and an orderly price formation process. The FSMA took into consideration the specific liquidity profiles of sovereign bonds and assessed the potential impact of immediate post-transaction publication on market liquidity and price formation. The FSMA carefully considered the need to maintain a balance between transparency and market efficiency, in which it is important to ensure that supplementary deferrals remain fair and limited in scope and do not detract from the overall objectives of MiFIR. The FSMA recognizes that allowing the omission of the volume of a transaction for a limited period, namely, until the end of the trading day for transactions in Belgian sovereign bonds classified within Group 1, for transactions in Category 1, as defined in Delegated Regulation (EU) 2017/583, may facilitate the orderly execution of transactions, particularly in situations where publication after 15 minutes could adversely affect liquidity provision or the functioning of the market. This decision was taken in line with the opinion of the EFC Sub-Committee on EU Sovereign Debt Markets (ESDM). In accordance with Article 11 (3) of MiFIR, the FSMA will monitor of the implementation of the supplementary deferral measure that have been authorized on the basis of this decision, ensuring that the supplementary deferral measure continues to support both market transparency and the efficient functioning of the market for sovereign bonds. This decision is without prejudice to the application of the standard measures regarding deferral of post-trade transparency, as laid down in Article 11 (1) of MiFIR and supplemented by Delegated Regulation (EU) 2017/583, and is limited to the instruments and categories specified herein, namely, sovereign bonds classified within Group 1, for transactions in Category 1 (medium-sized, in liquid instruments), as defined in Table 2.6 of Annex III of Delegated Regulation (EU) 2017/583.

3/3 / FSMA_2026_12 of 28/04/2026 / FSMA Decision: Market participants and investment firms may apply a supplementary deferral measure in accordance with Article 11 (3) (a) of Regulation (EU) No 600/2014 (MiFIR), which is limited to the omission of the volume of individual transactions in Belgian sovereign bonds. The volume of such transactions must be published at the latest at the end of the trading day. This decision applies to Belgian sovereign bonds within Group 1, for transactions in Category 1 (medium-sized, in liquid instruments), as defined in Table 2.6 of Annex III of Delegated Regulation (EU) 2017/583, for which the FSMA is competent on the basis of Article 11 (3) of MiFIR. This decision enters into force on 4 May 2026.