U.K. – FCA MiFID Position Limits

On 26 October, FCA published position limits for commodity derivatives.

  • Follows 24 October, ESMA new opinion on FCA commodity position limits.
  • The limits apply to named commodity in aggregate with mini, Balmo, mini-Balmo.
  • Where Balance of Month (Balmo) has same contractual specifications as derivative.
  • If two contracts traded in different units, position applies to positions in aggregate.
  • New position limits include derivatives based on different types of coal, gas and oil.

E.U. – ESMA on UK Position Limits

On 24 October, ESMA issued opinion on FCA commodity position limits.

  • ESMA’s opinions agree nine position limits proposed by Financial Conduct Authority (FCA).
  • Covers ESMA opinion on exact position limit for commodity futures and options contracts.
  • On zinc, tin, nickel, lead, copper, aluminium, ICE white sugar, Robusta coffee and cocoa.
  • Found position limits by the FCA were consistent with the objectives established in MiFID.
  • NCAs set specific position limits for commodity derivatives and notify ESMA of their plan.
  • ESMA is also publishing a list of liquid contracts that will receive a bespoke position limit.


  • FCA’s spot month limit is 7,000 lots. This constitutes 19% of the reference amount used.
  • Baseline for spot month limit is 25% of deliverable supply as required by Art 9(1) RTS 21.
  • The other months limit amounts to 78,800 lots. Constitutes 14.5% of reference amount.


  • Spot month limit is 1,700 lots (22.9% of the deliverable supply) adjusted downward 1%.
  • The other months limit amounts to 4,750 of lots and represents 22.3 of the open interest.


  • Spot month limit is 25,150 lots (20% reference) adjusted downward by 3% for market size.
  • Other months limit amounts to 80,200 lots (21% reference) adjusted upward for expires.


  • Spot month limit is 4,950 lots (22.9% reference) adjusted downward by 2% for market size.
  • Other months limit amounts to 33,700 lots (19.5% reference) upward adjustment expires.


  • Spot month limit is 13,950 lots (17% reference) adjusted downward for large open interest.
  • Other months limit is 106,900 lots (18% reference) upwards adjustment for large expires.


  • Spot month limit is 47,450 lots (14.5% reference) – 3.5% downward adjustment for delays.
  • Other months limit is 202,950 reduced by 2% for large number of separate expires (228).

ICE White Sugar

  • FCA set baseline for spot month at 20% as this is a contract for food intended for humans.
  • With no adjustments this represents baseline of 20% with lots of 18,963 rounded to 18,950.

Robusta Coffee

  • Spot month limit is 19,700 lots (20% deliverable supply) definition includes 60 calendar days.
  • Limit set by FCA applies for entire spot month and is higher than ICE delivery limits applied.


  • Spot month limit is 48,350 lots (20% deliverable supply), month until expiry of next contract.
  • It does not necessarily include a set number of days. Other month limit is 102,550 lots (25%).


  • ESMA is of opinion that position limits comply with RTS 21 and with method in Art 57 MiFID II.