13 October 2026

Valerie Urbain

Chief Executive Officer

Euroclear

Hanna Vainio

Chief Executive Officer

Euroclear Finland & Euroclear Sweden

Dear M s Urbain and M s Vainio,

Re: Establishing direct CSD links between Euroclear Sweden and Nasdaq CSD SE

The Ministers of Finance of Estonia, Latvia and Lithuania would like to express our joint

interest in exploring the feasibility of establishing operational direct settlement links

between Euroclear Sweden and Nasdaq CSD SE, in order to enable double listing of

Baltic high -growth companies, including the region's emerging unicorns , on Nordic

markets.

We believe this represents an important step towards a more integrated Nordic -Baltic

capital market, capable of supporting the next generation of regional growth

companies and responding to growing international investor demand for investment

opportunities across the region.

The European Commission’s Savings and Investments Union (SIU) strategy, adopted on

19 March 2025, identifies fragmented post -trade infrastructure as one of the principal

obstacles to a functioning single capital market and places the integration of trading

and post -trading infrastructures as an important element of its 2025 –2027 work

programme. Within the Nordic –Baltic region, the absence of direct settlement

connectivity between Sweden and the Baltic states represents precisely the type of

friction that th e SIU framework is designed to eliminate.

Sweden, one of the largest investors in the Baltic states in terms of FDI, has the

opportunity to serve as a natural complement to the Baltic capital markets — offering

institutional depth, a broad investor base and a mature listing infrastructure. The Bal tic

markets, in turn, offer Sweden a growing pipeline of issuers and a closer link to one of

Europe’s most dynamic small -economy regions. The economic rationale is mutual and

complementary, and fully aligns with Euroclear Bank’s action plan to deliver a tr ue

single market for post -trade activities as part of its contribution to SIU’s ambitious goal

to foster an open and interconnected European capital markets architecture.

In June 2026, Estonia, Latvia and Lithuania signed a Memorandum of Understanding

(MoU) with the EBRD in respect of their cooperation for the expansion of the pan -Baltic

Capital Market, that was also welcomed by the European Commission. Among its

objectives , the MoU aims to strengthen links and enhance interoperability between

Nasdaq CSD and other central securities depositories, facilitating cross -border

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settlement, improving market access, and supporting deeper capital market integration

across the region.

The Baltic exchanges in Tallinn, Riga and Vilnius are essential financial institutions . They

provide the primary venue for domestic price discovery, support capital raising for local

issuers across the full spectrum of company sizes, and enable Baltic citizens to

participate as shareholders in their own economies. Building a broad domestic investor

base, including retail participation, is a strategic priority for all three governments.

Achieving this objective, however, depends on stronger connectivity with deeper Nordic

and European pools of capital. The goal is not to replace national exchanges, but to

reinforce them through post -trade infrastructure that enables a single share class t o be

held, traded and settled seamlessly across Baltic and Nordic markets. Enhanced

interoperability would preserve and strengthen local markets while allowing capital to

flow more efficiently across the region, improving liquidity, market access and

inves tment opportunities for issuers and investors alike.

The urgency of addressing this issue is underscored by the growing number of Baltic

companies that have outgrown their domestic markets and require access to deeper

pools of capital to finance continued regional and international expansion. Without an

effe ctive pathway to larger capital markets, many successful firms ultimately relocate

their headquarters outside the Baltics, and in some cases outside the European Union.

For transactions above a certain scale, access to Stockholm's liquidity pool is often a

prerequisite for achieving an efficient valuation. At the same time, maintaining access

to domestic investors remains critical. The objective is therefore not to choose between

Baltic and Nordic markets, but to connect them more effectively. In the absenc e of

direct settlement connectivity, companies pursuing dual listings must rely on

depositary receipt structures or other workarounds. While these solutions are feasible,

they fragment liquidity across multiple order books, increase costs for issuers, crea te

friction for investors, and weaken the price discovery benefits that an integrated

market would provide. Across a multi -year issuance pipeline, these costs become

material and largely avoidable.

There is strong industry and political support across the Baltic States for closing this

gap. Nordic investors already have significant economic exposure to the region,

particularly through the financial sector, but also across telecommunications, ICT, ret ail,

real estate, and manufacturing. Strengthening market connectivity would build on

these existing ties, facilitating investment flows, supporting capital market

development, and deepening economic integration between the Baltic and Nordic

regions.

Thus, we respectfully invite Euroclear Sweden to:

• Explore the feasibility of establishing direct CSD links with Nasdaq CSD SE

covering Estonia, Latvia and Lithuania at the earliest opportunity, with a view to

operational implementation during the first half of 2027;

• Engage with Nasdaq CSD SE, Finansinspektionen and the relevant competent

authorities in the Baltic states to develop a joint implementation roadmap;

• Treat this project as a strategic priority within Euroclear Sweden’s current work

programme, consistent with the shared Nordic –Baltic ambition to build an

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integrated regional capital market in which national exchanges and the

Stockholm venue operate as complementary, fully interoperable infrastructure,

and with Euroclear Bank’s SIU -related action plan.

We stand ready to engage constructively, facilitate dialogue among stakeholders, and

provide any regulatory, policy or technical support required to advance this initiative.

We firmly believe that the establishment of such links at the earliest possible

op portunity would be in the common interest of issuers, investors, market

infrastructure providers and public authorities across the region.

We would be grateful for your support in facilitating this dialogue and remain at your

disposal should you require any further information.

Yours sincerely,

Jürgen Ligi Minister of Finance of the Republic of

Estonia

Māris Kučinskis Minister of Finance of the Republic of

Latvia

Taurimas Valys Minister of Finance of the Republic of

Lithuania

Andreea Moraru Managing Director, Central Europe and

Baltic States, EBRD

Cc: Niklas Wykman

Minister for Financial Markets

Ministry of Finance, Sweden

Johan Almenberg

Director General

Financial Supervisory Authority, Sweden

Paulina Dejmek Hack

Director General

Directorate General for Financial Stability, Financial Services and Capital Markets Union

European Commission

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