On September 16, ISDA and BBA submitted their response to the ESMA consultation paper entitled “Draft Regulatory Technical Standards on contracts having a direct, substantial and foreseeable effect within the Union and non-evasion of provisions of EMIR”
Documents (1) for ISDA-BBA response to the ESMA CP “Draft Regulatory Technical Standards on contracts having a direct, substantial and foreseeable effect within the Union and non-evasion of provisions of EMIR”
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ISDA In Review – October 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in October 2026.
ISDA Recommendations on EMIR under MISP
On November 2, ISDA published its recommendations on the European Parliament compromise amendments to the European Market Infrastructure Regulation (EMIR) under the Market Integration and Supervision Package (MISP). The briefing covers five areas: transaction reporting (Article 9), non-financial counterparties (Article...
Response on UK MIFIR Reporting Guidelines
On November 6, ISDA responded to the Financial Conduct Authority’s (FCA) consultation CP26/34 ‘Preparing for the new transaction reporting regime’ on the upcoming changes to the UK Markets in Financial Instruments Regulation (MIFIR) transaction reporting regime, as set out in...
Response on Transaction Reporting and Transparency
On October 30, ISDA submitted comments on the European Parliament’s (EP) proposed transaction reporting and transparency-related amendments to the European Commission’s Market Integration and Supervision Package (MISP). On transaction reporting, ISDA commends the EP’s ambition but cautions against trying to...