Post-trade risk reduction has become increasingly common as a means to reduce risks in the derivatives market. Portfolio compression is a case in point: offsetting trades between multiple parties are torn up, which reduces the size of gross exposures, in turn reducing systemic risk. Over €1,000 trillion in derivatives exposures has been eliminated in this manner.
Regulators recognize the value of compression. Under the European Market Infrastructure Regulation (EMIR), market participants with more than 500 over-the-counter (OTC) trades on their books are required to examine the possibility of performing portfolio compression twice a year.
However, EMIR simultaneously disincentivizes use of this service by requiring administrative trades that result from compression, and which fall under the clearing mandate, to be cleared. This limits the ability of participants to perform compression and reduce risk.
The same is true of other post-trade risk reduction services like counterparty rebalancing. This involves inserting new, market-risk neutral transactions into netting sets to reduce risk exposures between counterparties. This decreases counterparty credit risk and therefore reduces systemic risk. However, those new transactions are required to be cleared if they are subject to the clearing obligation, preventing counterparty rebalancing risk reduction from taking place. As a result, counterparty rebalancing today is only limited to FX derivatives, which are not subject to the clearing obligation. Over €100 billion in counterparty credit risk has been reduced in this manner.
ISDA, the EBF, ICMA and ISLA believe EMIR should be amended as part of the Regulatory Fitness and Performance program (REFIT) to allow non-price forming, market-risk neutral transactions that result from post-trade risk reduction services to be exempted from the clearing obligation.
To read the full whitepaper, click on the link below.
Documents (1) for Incentivizing Post-trade Risk Reduction
Latest
Market Transformation – IQ May 2026
On the 250th anniversary of American independence, this year’s ISDA Annual General Meeting (AGM) was held in Boston, a city that played a prominent role in the American Revolution. In his opening remarks, ISDA chief executive Scott O’Malia drew a...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Letter to EC and ESMA on Derivatives Framework
On March 27, ISDA sent a letter to the European Commission (EC) and the European Securities and Markets Authority (ESMA) to highlight several technical issues arising from the interaction between the delegated regulation (EU) 2025/1003 on identifying reference data to...
Response on Proposed Changes to Transaction Rules
On May 22, ISDA and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association submitted a joint response to the Australian Securities and Investments Commission's (ASIC) consultation on proposed changes to the ASIC Derivative Transaction Rules (Reporting)...
