ESMA has proposed amendments to its draft RTS on transparency requirements and position limits in response to proposed amendments by the Commission to the draft RTS in the form of two opinions. In its first opinion on draft RTS on transparency requirements in respect of bonds, structured finance products, emission allowances and derivatives under MiFIR, ESMA states that it is supportive of a phase-in for the liquidity criterion "average daily number of trades" for determining the liquidity status of bonds, and the trade percentile for determining the pre-trade size specific to the instrument for certain non-equity classes. However, for the implementation of the phase-in, ESMA proposes an alternative approach to the one suggested by the European Commission. In the second opinion on draft RTS on methodology for calculation and the application of position limits for commodity derivatives traded on trading venues and economically equivalent OTC contracts, ESMA states that it is supportive of most of the proposals suggested by the Commission and has revised the position limits accordingly.