STEP DECLINES TO 43.1%: WHY EUROPEAN CP/CD NEEDS FULL LABEL DATA AGREEMENT

STEP Captures Less Than Half the European Market: STEP–labelled CP/CD outstandings stood at EUR 581.1bn in August 2026 (–4.5% YoY), accounting for 43.1% of the aggregate EUR 1,348.2bn European CP/CD market. With 56.9% of outstandings sitting outside the framework—including the vast majority of ABCP—official STEP statistics provide a structurally incomplete view of total short-term funding.

Official STEP Data Systematically Overweights Banks and SSAs: STEP adoption is heavily skewed toward financial institutions (57.9% of total FIG CP/CD outstandings) and public issuers (28.1%), while remaining thinly used by corporates (10.9%). Relying on STEP as a market proxy overstates bank and sovereign participation while underrepresenting corporate and securitised funding channels.

STEP Data Alone Obscures Entity-Level Risk: While ECB STEP series provide high-quality data for labelled programmes, major issuers frequently issue through parallel non-STEP channels. Discrepancies are material—for instance, Barclays Bank PLC holds EUR 12,924mn in STEP outstandings compared with EUR 43,796mn across its broader short-term debt stack—leaving critical gaps for counterparty, liquidity, and Article 18 MMF concentration risk analysis.

Data Agreement is Essential for Regulatory Surveillance: With 64 of 216 active STEP programmes currently sitting unused with zero outstandings, fragmentation across reporting silos continues to generate duplication and complexity. Consolidating official ECB statistics with granular, ISIN-level databases like CMDportal is necessary to establish a unified, real-time map of European money market risk.