CFDs referencing futures

[ESMA 35-36-1262 Q&AS on Product intervention, Q&A nr 5.7] Annex I to the ESMA CFD Decision sets out the different initial margin percentages by type of underlying. The different types of underlyings do not explicitly refer to CFDs referencing futures contracts. Nevertheless, as futures also give the holder an exposure to a specific underlying this specific underlying should be considered for the purpose of the ESMA CFD Decision. For example, the minimum initial margin percentage for a CFD on a future on the USD/EUR pair is 3.33% of the notional value of the CFD. For this purpose ESMA considers a CFD on the future on the USD/EUR to have a type of underlying that is a major currency.