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How to Write the “Overcoming Challenges” Essay + Examples

What’s covered:.

  • What is the Overcoming Challenges Essay?
  • Real Overcoming Challenges Essay Prompts
  • How to Choose a Topic
  • Writing Tips

Overcoming Challenges Essay Examples

  • Where to Get Your Essay Edited

While any college essay can be intimidating, the Overcoming Challenges prompt often worries students the most. Those students who’ve been lucky enough not to experience trauma tend to assume they have nothing worth saying. On the other hand, students who’ve overcome larger obstacles may be hesitant to talk about them.

Regardless of your particular circumstances, there are steps you can take to make the essay writing process simpler. Here are our top tips for writing the overcoming challenges essay successfully.

What is the “Overcoming Challenges” Essay?

The overcoming challenges prompt shows up frequently in both main application essays (like the Common App) and supplemental essays. Because supplemental essays allow students to provide schools with additional information, applicants should be sure that the subject matter they choose to write about differs from what’s in their main essay.

Students often assume the overcoming challenges essay requires them to detail past traumas. While you can certainly write about an experience that’s had a profound effect on your life, it’s important to remember that colleges aren’t evaluating students based on the seriousness of the obstacle they overcame.

On the contrary, the goal of this essay is to show admissions officers that you have the intelligence and fortitude to handle any challenges that come your way. After all, college serves as an introduction to adult life, and schools want to know that the students they admit are up to the task. 

Real “Overcoming Challenges” Essay Prompts

To help you understand what the “Overcoming Challenges” essay looks like, here are a couple sample prompts.

Currently, the Common Application asks students to answer the following prompt in 650 words or less:

“The lessons we take from obstacles we encounter can be fundamental to later success. Recount a time when you faced a challenge, setback, or failure. How did it affect you, and what did you learn from the experience?”

For the past several years, MIT has prompted students to write 200 to 250 words on the following:

“Tell us about the most significant challenge you’ve faced or something important that didn’t go according to plan. How did you manage the situation?”

In both cases, the prompts explicitly ask for your response to the challenge. The event itself isn’t as important as how it pushed you to grow.

How to Choose a Topic for an Essay on Overcoming Challenges

When it comes to finding the best topic for your overcoming challenges essays, there’s no right answer. The word “challenge” is ambiguous and could be used to reference a wide range of situations from prevailing over a bully to getting over your lifelong stage fright to appear in a school musical. Here are some suggestions to keep in mind when selecting an essay subject.

1. Avoid trivial or common topics

While there aren’t many hard-and-fast rules for choosing an essay topic, students should avoid overdone topics.

These include:

  • Working hard in a challenging class
  • Overcoming a sports injury
  • Moving schools or immigrating to the US
  • Tragedy (divorce, death, abuse)

Admissions officers have read numerous essays on the subject, so it’s harder for you to stand out (see our full list of cliché college essay topics to avoid ). If events like these were truly formative to you, you can still choose to write about them, but you’ll need to be as personal as possible. 

It’s also ideal if you have a less traditional storyline for a cliché topic; for example, if your sports injury led you to discover a new passion, that would be a more unique story than detailing how you overcame your injury and got back in the game.

Similarly, students may not want to write about an obstacle that admissions committees could perceive as low stakes, such as getting a B on a test, or getting into a small fight with a friend. The goal of this essay is to illustrate how you respond to adversity, so the topic you pick should’ve been at least impactful on your personal growth.

2. Pick challenges that demonstrate qualities you want to highlight

Students often mistakenly assume they need to have experienced exceptional circumstances like poverty, an abusive parent, or cancer to write a good essay. The truth is that the best topics will allow you to highlight specific personal qualities and share more about who you are. The essay should be less about the challenge itself, and more about how you responded to it.

Ask yourself what personality traits you want to emphasize, and see what’s missing in your application. Maybe you want to highlight your adaptability, for example, but that isn’t clearly expressed in your application. In this case, you might write about a challenge that put your adaptability to the test, or shaped you to become more adaptable.

Here are some examples of good topics we’ve seen over the years:

  • Not having a coach for a sports team and becoming one yourself
  • Helping a parent through a serious health issue
  • Trying to get the school track dedicated to a coach
  • Having to switch your Model UN position last-minute

Tips for Writing an Essay About Overcoming Challenges

Once you’ve selected a topic for your essays, it’s time to sit down and write. For best results, make sure your essay focuses on your efforts to tackle an obstacle rather than the problem itself. Additionally, you could avoid essay writing pitfalls by doing the following:

1. Choose an original essay structure

If you want your overcoming challenges essay to attract attention, aim to break away from more traditional structures. Most of these essays start by describing an unsuccessful attempt at a goal and then explain the steps the writer took to master the challenge. 

You can stand out by choosing a challenge you’re still working on overcoming, or focus on a mental or emotional challenge that spans multiple activities or events. For example, you might discuss your fear of public speaking and how that impacted your ability to coach your brother’s Little League team and run for Student Council. 

You can also choose a challenge that can be narrated in the moment, such as being put on the spot to teach a yoga class. These challenges can make particularly engaging essays, as you get to experience the writer’s thoughts and emotions as they unfold.

Keep in mind that you don’t necessarily need to have succeeded in your goal for this essay. Maybe you ran for an election and lost, or maybe you proposed a measure to the school board that wasn’t passed. It’s still possible to write a strong essay about topics like these as long as you focus on your personal growth. In fact, these may make for even stronger essays since they are more unconventional topics.

2. Focus on the internal

When writing about past experiences, you may be tempted to spend too much time describing specific people and events. With an Overcoming Challenges essay though, the goal is to focus on your thoughts and feelings.

For example, rather than detail all the steps you took to become a better public speaker, use the majority of your essay to describe your mental state as you embarked on the journey to achieving your goals. Were you excited, scared, anxious, or hopeful? Don’t be afraid to let the reader in on your innermost emotions and thoughts during this process.

3. Share what you learned 

An Overcoming Challenges essay should leave the reader with a clear understanding of what you learned on your journey, be it physical, mental, or emotional. There’s no need to explicitly say “this experience taught me X,” but your essay should at least implicitly share any lessons you learned. This can be done through your actions and in-the-moment reflections. Remember that the goal is to show admissions committees why your experiences make you a great candidate for admission. 

Was I no longer the beloved daughter of nature, whisperer of trees? Knee-high rubber boots, camouflage, bug spray—I wore the g arb and perfume of a proud wild woman, yet there I was, hunched over the pathetic pile of stubborn sticks, utterly stumped, on the verge of tears. As a child, I had considered myself a kind of rustic princess, a cradler of spiders and centipedes, who was serenaded by mourning doves and chickadees, who could glide through tick-infested meadows and emerge Lyme-free. I knew the cracks of the earth like the scars on my own rough palms. Yet here I was, ten years later, incapable of performing the most fundamental outdoor task: I could not, for the life of me, start a fire. 

Furiously I rubbed the twigs together—rubbed and rubbed until shreds of skin flaked from my fingers. No smoke. The twigs were too young, too sticky-green; I tossed them away with a shower of curses, and began tearing through the underbrush in search of a more flammable collection. My efforts were fruitless. Livid, I bit a rejected twig, determined to prove that the forest had spurned me, offering only young, wet bones that would never burn. But the wood cracked like carrots between my teeth—old, brittle, and bitter. Roaring and nursing my aching palms, I retreated to the tent, where I sulked and awaited the jeers of my family. 

Rattling their empty worm cans and reeking of fat fish, my brother and cousins swaggered into the campsite. Immediately, they noticed the minor stick massacre by the fire pit and called to me, their deep voices already sharp with contempt. 

“Where’s the fire, Princess Clara?” they taunted. “Having some trouble?” They prodded me with the ends of the chewed branches and, with a few effortless scrapes of wood on rock, sparked a red and roaring flame. My face burned long after I left the fire pit. The camp stank of salmon and shame. 

In the tent, I pondered my failure. Was I so dainty? Was I that incapable? I thought of my hands, how calloused and capable they had been, how tender and smooth they had become. It had been years since I’d kneaded mud between my fingers; instead of scaling a white pine, I’d practiced scales on my piano, my hands softening into those of a musician—fleshy and sensitive. And I’d gotten glasses, having grown horrifically nearsighted; long nights of dim lighting and thick books had done this. I couldn’t remember the last time I had lain down on a hill, barefaced, and seen the stars without having to squint. Crawling along the edge of the tent, a spider confirmed my transformation—he disgusted me, and I felt an overwhelming urge to squash him. 

Yet, I realized I hadn’t really changed—I had only shifted perspective. I still eagerly explored new worlds, but through poems and prose rather than pastures and puddles. I’d grown to prefer the boom of a bass over that of a bullfrog, learned to coax a different kind of fire from wood, having developed a burn for writing rhymes and scrawling hypotheses. 

That night, I stayed up late with my journal and wrote about the spider I had decided not to kill. I had tolerated him just barely, only shrieking when he jumped—it helped to watch him decorate the corners of the tent with his delicate webs, knowing that he couldn’t start fires, either. When the night grew cold and the embers died, my words still smoked—my hands burned from all that scrawling—and even when I fell asleep, the ideas kept sparking—I was on fire, always on fire.

This essay is an excellent example because the writer turns an everyday challenge—starting a fire—into an exploration of her identity. The writer was once “a kind of rustic princess, a cradler of spiders and centipedes,” but has since traded her love of the outdoors for a love of music, writing, and reading. 

The story begins in media res , or in the middle of the action, allowing readers to feel as if we’re there with the writer. One of the essay’s biggest strengths is its use of imagery. We can easily visualize the writer’s childhood and the present day. For instance, she states that she “rubbed and rubbed [the twigs] until shreds of skin flaked from my fingers.”

The writing has an extremely literary quality, particularly with its wordplay. The writer reappropriates words and meanings, and even appeals to the senses: “My face burned long after I left the fire pit. The camp stank of salmon and shame.” She later uses a parallelism to cleverly juxtapose her changed interests: “instead of scaling a white pine, I’d practiced scales on my piano.”

One of the essay’s main areas of improvement is its overemphasis on the “story” and lack of emphasis on the reflection. The second to last paragraph about changing perspective is crucial to the essay, as it ties the anecdote to larger lessons in the writer’s life. She states that she hasn’t changed, but has only shifted perspective. Yet, we don’t get a good sense of where this realization comes from and how it impacts her life going forward. 

The end of the essay offers a satisfying return to the fire imagery, and highlights the writer’s passion—the one thing that has remained constant in her life.

“Getting beat is one thing – it’s part of competing – but I want no part in losing.” Coach Rob Stark’s motto never fails to remind me of his encouragement on early-morning bus rides to track meets around the state. I’ve always appreciated the phrase, but an experience last June helped me understand its more profound, universal meaning.

Stark, as we affectionately call him, has coached track at my high school for 25 years. His care, dedication, and emphasis on developing good character has left an enduring impact on me and hundreds of other students. Not only did he help me discover my talent and love for running, but he also taught me the importance of commitment and discipline and to approach every endeavor with the passion and intensity that I bring to running. When I learned a neighboring high school had dedicated their track to a longtime coach, I felt that Stark deserved similar honors.

Our school district’s board of education indicated they would only dedicate our track to Stark if I could demonstrate that he was extraordinary. I took charge and mobilized my teammates to distribute petitions, reach out to alumni, and compile statistics on the many team and individual champions Stark had coached over the years. We received astounding support, collecting almost 3,000 signatures and pages of endorsements from across the community. With help from my teammates, I presented this evidence to the board.

They didn’t bite. 

Most members argued that dedicating the track was a low priority. Knowing that we had to act quickly to convince them of its importance, I called a team meeting where we drafted a rebuttal for the next board meeting. To my surprise, they chose me to deliver it. I was far from the best public speaker in the group, and I felt nervous about going before the unsympathetic board again. However, at that second meeting, I discovered that I enjoy articulating and arguing for something that I’m passionate about.

Public speaking resembles a cross country race. Walking to the starting line, you have to trust your training and quell your last minute doubts. When the gun fires, you can’t think too hard about anything; your performance has to be instinctual, natural, even relaxed. At the next board meeting, the podium was my starting line. As I walked up to it, familiar butterflies fluttered in my stomach. Instead of the track stretching out in front of me, I faced the vast audience of teachers, board members, and my teammates. I felt my adrenaline build, and reassured myself: I’ve put in the work, my argument is powerful and sound. As the board president told me to introduce myself, I heard, “runners set” in the back of my mind. She finished speaking, and Bang! The brief silence was the gunshot for me to begin. 

The next few minutes blurred together, but when the dust settled, I knew from the board members’ expressions and the audience’s thunderous approval that I had run quite a race. Unfortunately, it wasn’t enough; the board voted down our proposal. I was disappointed, but proud of myself, my team, and our collaboration off the track. We stood up for a cause we believed in, and I overcame my worries about being a leader. Although I discovered that changing the status quo through an elected body can be a painstakingly difficult process and requires perseverance, I learned that I enjoy the challenges this effort offers. Last month, one of the school board members joked that I had become a “regular” – I now often show up to meetings to advocate for a variety of causes, including better environmental practices in cafeterias and safer equipment for athletes.

Just as Stark taught me, I worked passionately to achieve my goal. I may have been beaten when I appealed to the board, but I certainly didn’t lose, and that would have made Stark proud.

While the writer didn’t succeed in getting the track dedicated to Coach Stark, their essay is certainly successful in showing their willingness to push themselves and take initiative.

The essay opens with a quote from Coach Stark that later comes full circle at the end of the essay. We learn about Stark’s impact and the motivation for trying to get the track dedicated to him.

One of the biggest areas of improvement in the intro, however, is how the essay tells us Stark’s impact rather than showing us: His care, dedication, and emphasis on developing good character has left an enduring impact on me and hundreds of other students. Not only did he help me discover my talent and love for running, but he also taught me the importance of commitment and discipline and to approach every endeavor with the passion and intensity that I bring to running.

The writer could’ve helped us feel a stronger emotional connection to Stark if they had included examples of Stark’s qualities, rather than explicitly stating them. For example, they could’ve written something like: Stark was the kind of person who would give you gas money if you told him your parents couldn’t afford to pick you up from practice. And he actually did that—several times. At track meets, alumni regularly would come talk to him and tell him how he’d changed their lives. Before Stark, I was ambivalent about running and was on the JV team, but his encouragement motivated me to run longer and harder and eventually make varsity. Because of him, I approach every endeavor with the passion and intensity that I bring to running.

The essay goes on to explain how the writer overcame their apprehension of public speaking, and likens the process of submitting an appeal to the school board to running a race. This metaphor makes the writing more engaging and allows us to feel the student’s emotions.

While the student didn’t ultimately succeed in getting the track dedicated, we learn about their resilience and initiative: I now often show up to meetings to advocate for a variety of causes, including better environmental practices in cafeterias and safer equipment for athletes.

Overall, this essay is well-done. It demonstrates growth despite failing to meet a goal, which is a unique essay structure. The running metaphor and full-circle intro/ending also elevate the writing in this essay.

Where to Get Your Overcoming Challenges Essay Edited

The Overcoming Challenges essay is one of the trickier supplemental prompts, so it’s important to get feedback on your drafts. That’s why we created our free Peer Essay Review tool , where you can get a free review of your essay from another student. You can also improve your own writing skills by reviewing other students’ essays. 

If you want a college admissions expert to review your essay, advisors on CollegeVine have helped students refine their writing and submit successful applications to top schools. Find the right advisor for you to improve your chances of getting into your dream school!

Related CollegeVine Blog Posts

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Nurses Week 2024: Support and celebrate your staff

For Nurses Week 2024, we're celebrating the remarkable impact nurses have on the organizations and communities they serve . Advisory Board 's Allyson Paiewonsky explains how nursing leaders can support their staff and provides resources to help leaders address key challenges facing the nursing workforce today. 

3 underlying causes of nurse recruitment and retention challenges

Today marks the first day of Nurses Week 2024 — an annual commitment established by the American Nurses Association (ANA) to recognize the invaluable contributions of nurses.

This year's theme, "Nurses Make the Difference," coincides with the ongoing efforts of C-suite leaders to stabilize their nursing workforces. Despite significant time and resource investments, overall RN turnover remains too high and first-year turnover is particularly challenging. As a result, nursing leaders are understandably concerned about the RN workforce shortage and focused on addressing urgent challenges.

As nursing leaders navigate the challenges facing their workforces, it is vital for them to provide support and guidance. Here are three key opportunities nursing leaders can leverage in 2024 and beyond. 

1. Prioritize making improvements to nursing work environments

The workforce crisis has highlighted the undeniable difference nurses make in care teams and the overall success of their organizations. Nurses' contributions extend far beyond patient care — they play a central part in driving the success of healthcare organizations, influencing patient outcomes and satisfaction, and maintaining operational excellence.

It is crucial that hospitals and health systems recognize their importance by prioritizing improvements to nurses' work environments. This includes ensuring adequate staffing levels, manageable workloads, and access to necessary emotional health and wellbeing resources. By investing in nurses' work environments, we can enhance job satisfaction, reduce burnout, and improve patient safety and quality of care.

We've put together resources to help healthcare leaders honor nurses by making meaningful impacts in their work environments:

  • 5 ongoing challenges of the workforce crisis — and what to do about them
  • How Allegheny Health Network's Blended Nursing Model Addresses Staffing Shortages

2. Deploy AI and technology to streamline workflows

Nurse workflows have become inundated with repetitive administrative tasks that detract from their clinical training. In an era of technological advancements, artificial intelligence (AI) has the potential to revolutionize nursing workflows. By leveraging AI-powered tools, nurses can streamline administrative tasks, allowing them to focus more on direct patient care. For instance, AI-assisted triaging, automated vital sign data entry, and clinical decision support can augment nursing workflows, thereby freeing up valuable time for nurses to spend with their patients.

While AI is well-positioned to support nurses, it should not be a replacement for nurses. AI can't comprehensively fulfill a nurse's full scope of practice — nursing is much more than completing tasks, as it involves building relationships and critical thinking. Nurses and their unique expertise make a difference in patient care.

When leaders are thinking about implementing AI and other technologies, it is crucial to include nurses in selecting and implementing technology that will impact their day-to-day work. Nurses should actively be involved in tech decision-making and implementation if we want those investments to succeed.

While leaders should not leverage technology to replace nurses, they should use it to help nurses practice at the top of their licenses. Here are a few resources to help leaders understand how technology can streamline workflows and address workforce challenges:

  • AI nurses? Inside Nvidia, Hippocratic AI's new partnership
  • 3 ways AI can help nurses
  • How technology can help solve the workforce crisis

3. Leverage virtual nursing to ease workforce shortage pain points

Virtual nursing offers a transformative solution that not only addresses a shortage of nurses but also provides crucial support to novice nurses. By offloading administrative tasks or delegating specific care responsibilities to a virtual nurse, bedside nurses receive more time for direct patient interaction.

Additionally, through virtual platforms, novice nurses can collaborate with experienced mentors, seek guidance, and receive real-time feedback. This virtual support system helps bridge the experience gap and empowers novice nurses to gain confidence and competence in their practice. We compiled a list of resources to help leaders understand the benefits of virtual nursing, with guidance on how to implement a virtual nursing program:

A detailed look at the top 2 models for virtual nursing care

  • Virtual nursing: What it is, and why we need it
  • Your how-to guide for implementing a virtual nursing program

Ultimately, nurse leaders shouldn't act alone in addressing these concerns — other members of the C-suite at hospitals and health systems need to lend their support as well. The best way to do this is to give nursing leaders the ability to implement innovative solutions to best support their nurses. To learn more about how health systems can help address nursing leaders' concerns, read our take on what health systems should know about nurse leaders' priorities.

On May 9, join us for a transformative webinar that challenges the conventional wisdom on leadership development. Also, tune into Radio Advisory on May 7 for our podcast episode celebrating Nurses Week.

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Allyson Paiewonsky, MPH

Posted on May 06, 2024

Updated on May 06, 2024

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4 key concerns of nurse leaders — and how the rest of the C-suite can help

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'Make My Day, Pal': Joe Biden Challenges Donald Trump To A Presidential Debate

Senior Politics Reporter, HuffPost

Senior Political Reporter, HuffPost

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President Joe Biden and former President Donald Trump agreed on Wednesday to meet for presidential debates in June and September, after Biden posted a video challenging the presumptive GOP nominee to square off and “make my day, pal.”

Their plans include a CNN debate on June 27 and an ABC debate on Sept. 10. Those are the only details on the events so far. Trump also suggested a third debate in October on Fox News, but Biden’s team said they only agreed to two.

“President Biden made his terms clear for two one-on-one debates, and Donald Trump accepted those terms. No more games. No more chaos, no more debate about debates,” said Jen O’Malley Dillon, chair of the 2024 Biden-Harris campaign.

Trump, in a post to Truth Social on Wednesday morning, said he was “ready and willing” to face off against Biden at least twice. “Let’s get ready to Rumble!!!” Trump wrote.

The two presumptive major-party nominees agreed on the dates themselves, circumventing the Commission on Presidential Debates. The nonpartisan commission, the group that normally handles organizing the events, had wanted to set them for after the start of early voting in the fall, which both campaigns objected to. Now, one of the debates is slated to happen before either Biden or Trump officially becomes their respective party’s presidential nominee at conventions over the summer.

Donald Trump lost two debates to me in 2020. Since then, he hasn’t shown up for a debate. Now he’s acting like he wants to debate me again. Well, make my day, pal. pic.twitter.com/AkPmvs2q4u — Joe Biden (@JoeBiden) May 15, 2024

Biden taunted Trump in a video posted on X: “Donald Trump lost two debates to me in 2020 and since then he hasn’t shown up to debate. Now he’s acting like he wants to debate me again,” Biden said, referring to their two fiery pandemic-era meetings, including one in Cleveland that sparked a COVID outbreak .

“I hear you’re free on Wednesdays,” Biden teased, referring to the day that Trump has off from his hush money trial in New York City. Trump’s legal troubles have prevented him from campaigning as intensely as he has in past elections.

In a matter of hours and with little back and forth on social media, the two candidates reached a quick consensus. But their posts underscored what’s expected to be a series of nasty meetings ahead of a bitterly contested election.

“I would strongly recommend more than two debates and, for excitement purposes, a very large venue, although Biden is supposedly afraid of crowds – That’s only because he doesn’t get them,” Trump wrote.

Republican senators suggested that Biden asked for the debate because polls show Biden trailing Trump .

“They see that their numbers are not improving and their strategy of keeping Trump bottled up in courtrooms is not working for them,” Cynthia Lummis (R-Wy.) told HuffPost.

Mitt Romney (R-Utah), a Trump critic who is retiring at the end of the year, says the debates should be “entertaining” and “informative.”

“Like the two old guys on the Muppets,” he said.

Crooked Joe Biden is the WORST debater I have ever faced - He can’t put two sentences together! Crooked is also the WORST President in the history of the United States, by far. It’s time for a debate so that he can explain to the American People his highly destructive Open Border… — Donald J. Trump Posts From His Truth Social (@TrumpDailyPosts) May 15, 2024

Trump refused one of the 2020 presidential debates when organizers announced it would be held virtually amid the pandemic, though he and Biden still faced each other twice prior to the last election. The former president also skipped the 2024 GOP primary debates.

But in recent months, Trump has been taunting Biden on the campaign trail, calling for more debates than usual and placing an empty lectern on the stage at his rallies to represent where Biden could stand.

Trump also suggested a presidential debate at the courthouse in New York City, where he is on trial for falsifying business records related to hush money paid to silence adult film star Stormy Daniels.

“Anytime, anyplace,” Trump said of debating Biden at a rally earlier this year.

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It's official: Donald Trump will face Joe Biden this fall in the presidential election. As we face the most consequential presidential election of our time, HuffPost is committed to bringing you up-to-date, accurate news about the 2024 race. While other outlets have retreated behind paywalls, you can trust our news will stay free.

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On April 3, 2024, the European Securities Market Authority (ESMA) sent an update letter to the European Commission and other EU institutions on the uptake of distributed ledger technology by financial market infrastructures in the context of the DLT Pilot Regime ( Regulation (EU) 2022/8581 ).

This letter was sent and published instead of an interim report that ESMA is required to publish (see Article 15 of the DLT Pilot Regulation). ESMA must publish annual interim reports to (i) inform market participants on market functioning, (ii) address misconduct by DLT market operators, (iii) clarify Regulation applications, and (iv) update guidance based on DLT evolution.

FRANKFURT, GERMANY

The first such report was expected to be published by March 24 2024. However, since the DLT Pilot Regime entered into force on March 23 2023, no DLT market infrastructure has been authorised . This is concerning, as the regime was meant to facilitate innovative DLT projects, but the opposite seems true.

ESMA attributes the slow uptake to the regime's novelty. Yet, if we review the DLT ecosystem in the EU , we can reasonably easily determine numerous potential applicants. Besides the zero granted permissions, what is even more concerning is that there were only four official applications (one DLT TSS and one DLT MTF in Germany, one DLT SS in the Czech Republic, and one DLT TSS in the Netherlands). The respective NCAs are currently assessing these applications.

The fact that no DLT operators were granted permission to operate within the first year of their application and only four applications across the whole EU were submitted should prompt immediate attention from the European authorities, researchers, and the market. Indeed, ESMA itself has identified some challenges.

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Biden-trump debates: what to know as trump pushes for 2 more faceoffs, wwe smackdown results winners and grades with stratton vs belair, identified challenges by esma.

  • Innovative Solutions for Cash Settlement - In the absence of central bank digital currencies, the DLT Pilot Regime offers the opportunity for innovative cash settlement solutions, such as tokenised commercial bank money or e-money tokens. However, delays in MiCA authorisations have made it challenging for applicants to find cash leg providers. DLT SS/TSS operators can settle payments using e-money tokens issued by credit institutions.
  • Custody through Self-Hosted Wallets - Custody through self-hosted wallets in the DLT Pilot Regime requires further clarification. The regime covers a subset of financial instruments under MiFID II, while MiCA deals with non-financial crypto-assets, including e-money tokens. Regulatory expectations for custody services in DLT market infrastructures and the roles of entities, particularly regarding non-custodial "self-hosted wallets," need to be clarified to address potential overlaps with MiCA or MiFID II custody services.
  • Interoperability between DLT and traditional market infrastructures, as well as among DLT infrastructures, poses significant challenges. Due to technological and operational complexities, DLT MTF operators struggle to find authorised DLT TSS or DLT SS or access traditional CSDs.
  • Investor Protection - The DLT Pilot Regime allows NCAs to grant retail investors access to DLT market infrastructures under certain conditions, bypassing the MiFID II "obligation of intermediation." This requires additional investor protection measures due to the complex interaction between MiFID II and the DLT Pilot Regime. Retail investor access is limited to non-complex financial instruments, and further clarity is needed for consistent implementation across the EU. ESMA has requested the Commission's interpretation of these issues, including the treatment of pre-emptive subscription rights for shares on DLT platforms.
  • Competitiveness vis-à-vis Third-Country Regimes - Uncertainty about the DLT Pilot Regime's duration and low thresholds for DLT financial instruments undermine its competitiveness. Public assurance of the regime's extension and greater threshold flexibility could attract more applicants and ensure sufficient time for project implementation.

Response from the European Commission

In a letter dated April 3, 2024, European Commission briefly responded to the ESMA's letter stating that despite the slow start, only four applications are under review, highlighting the regime's potential. The Commission emphasised the DLT Pilot Regime's potential for fostering DLT-based market solutions, enhancing efficiency, reducing costs, and mitigating risks. The Commission reiterated its commitment to resolving implementation challenges and clarified that there is no expiration date for the regime, with no plans for termination. The Commission's focus remains on supporting innovation in financial markets. Thus addressing only one concern that ESMA stipulated.

Additional Considerations for ESMA

Besides the challenges identified by ESMA, there are additional concerns that might have caused the extremely limited number of applications. Undoubtedly, a significant barrier is the complexity and interoperability of the application process, which deters potential applicants. However, there may be a misalignment in the target audience - the operators. On one hand, the DLT Pilot Regime aims to foster innovation and enhance the DLT landscape. Yet, except where specific exemptions apply, most operators remain regulated by existing frameworks like MiFID II, MiFIR, MAR, or CSDR. This ultimately means that only regulated operators qualify to operate DLT market infrastructure. Any new operators will still need to obtain all the necessary permissions under the applicable law, with minimal exceptions, which is contrary to the idea of a sandbox.

The DLT Pilot Regime, intended to spur innovation, inadvertently favours established, regulated entities due to its complex application process and regulatory requirements. To truly foster innovation and support new entrants, it may be necessary to simplify the application process, reassess the regulatory framework, and open the DLT regime for unregulated operators. This will ensure the regime meets its original purpose of creating a more inclusive and innovative environment for DLT market infrastructures.

Alexandra Andhov

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