The International Swaps and Derivatives Association, Inc.1 (“ISDA”) is pleased to have the opportunity to comment on the European Market Infrastructure Regulation (“EMIR”), the proposed EU Commission regulation on OTC derivatives, central counterparties and trade repositories. ISDA is writing this letter to explain and emphasise the importance of EMIR having sufficient flexibility so as to accommodate indirect clearing and provide scope for guidance and practice from the European Securities and Market Authority (“ESMA”) in due course.
Documents (1) for ISDA-AFME commentary on indirect clearing under the EMIR – 29 July 2011
Latest
Data Integrity for Single-sided Reporting
On April 2, ISDA published a paper on why single-sided reporting does not compromise the quality and integrity of data received by supervisors. The paper addresses concerns among regulators that moving from dual-sided reporting would adversely affect the quality of...
Paper on Removal of SI Regime
On April 2, ISDA, the Association for Financial Markets in Europe (AFME) and the International Capital Market Association (ICMA) published an update to a paper, originally published in October 2025, on the practical implications of the systematic internalizer (SI) regime...
Measured Adjustments - IQ April 2026
Eighteen years on from the global financial crisis of 2008, the rollout of central clearing, margining of non-cleared derivatives trades and higher capital requirements has completely reshaped derivatives trading and risk management. But effective regulation requires regular monitoring to ensure...
ISDA In Review – March 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in March 2026.