Why Viridian is a regulated exchange

On 19 October 2026, Viridian started operating as a licensed Multilateral Trading Facility (MTF), supervised by the Dutch Authority for the Financial Markets (AFM). For our members this is more than a new label. It changes the rules the market runs on, who can access it, and how much they can trust it.

This piece explains why we chose regulation, what it gives participants, how AFS got here, and what changes day to day.

Why it was needed

Since MiFID II took effect in January 2018, EU emission allowances (EUAs) are financial instruments. Yet the way most compliance buyers access them has barely changed.

• Two-tier market – liquidity sits on the large exchanges, but membership there only pays off at high volumes. We estimate the large majority of the roughly 12,000 EU ETS compliance entities never reach that threshold.

• The rest trade off-exchange – smaller emitters buy through banks, brokers or bilateral deals, with less price transparency and little evidence of best execution.

• Compliance is not optional – every covered entity must surrender allowances each year, whatever its size. Access to a fair, transparent market should not depend on volume.

• More participants are coming – EU ETS 2 brings buildings and road transport into carbon trading from 2028, adding a large new group of mostly smaller obligated entities.

A regulated venue built for this group closes the gap: exchange-grade standards, without exchange-scale entry requirements.

What it means for participants

• Fair, non-discretionary trading – orders meet under published rules in a central limit order book. Every member sees the same prices and is treated the same way.

• Transparency – pre- and post-trade transparency gives members visible prices and a clear audit trail for every trade.

• Best execution, documented – trading on a regulated venue gives compliance and finance teams evidence that they bought at a fair market price.

• Supervised market integrity – market surveillance and market abuse controls under AFM supervision protect members from manipulation.

• Low barrier to entry – no volume threshold, and onboarding a new member takes about a day rather than months.

• One venue, more products – EUAs and Guarantees of Origin on the same platform, with more environmental products to follow.

The AFS journey

Viridian is the result of years of building regulated market infrastructure, step by step:

• 2018 – AFS OTF – AFS receives its Organised Trading Facility licence, the first of its kind in the Dutch market, for voice and chat trading.

• 2019 – MTF licence – AFS E-Venues B.V. is licensed by the AFM to operate a Multilateral Trading Facility.

• Early 2024 – Viridian launches – a digital platform for EUA trading, designed for compliance buyers of every size.

• July 2026 – Guarantees of Origin – GO trading goes live alongside EUAs.

• 19 October 2026 – Viridian goes live as an MTF – trading on Viridian now runs under the AFS E-Venues MTF licence.

A rare licence for carbon

The AFM register lists 14 licensed MTFs in the Netherlands. Almost all serve equities, bonds, rates, FX or digital-asset derivatives – venues such as Bloomberg, Tradeweb, MarketAxess, Cboe Europe and Turquoise.

Only one of them is used for EU carbon allowances: AFS E-Venues, the licence behind Viridian.

Source: AFM register of trading venues, checked October 2026.

What changes operationally

For members

• Membership under a rulebook – members join under the Viridian MTF rulebook, which sets out access, trading and conduct rules. A public version with a plain-language Q&A will follow on our website.

• Onboarding – KYC and eligibility checks as before, still completed in about a day.

• Order book trading – bids and offers from members and market makers meet in one central limit order book.

• Reporting handled by the venue – trade transparency and regulatory reporting are part of the venue's obligations, reducing the burden on members.

For AFS and Viridian

• Market surveillance – continuous monitoring of orders and trades for market abuse.

• Clear separation of roles – venue operation is kept separate from market-making and brokerage activity within AFS Group.

• Governance and controls – documented procedures, system resilience and ongoing AFM supervision.

The bottom line

Carbon compliance is mandatory for every covered company, so fair access to the carbon market should be too. As a regulated MTF, Viridian combines the protection of exchange rules with the accessibility smaller participants need.