Significant progress has been made in moving standardized derivatives trades to central counterparties (CCPs), in line with commitments made by the Group of 20 (G-20). Approximately 77% of interest rate derivatives notional outstanding is now cleared, according to the Bank for International Settlements.
The increased importance of CCPs has focused attention on the resiliency and oversight of these entities. In the European Union (EU), this has resulted in a series of measures, including a proposed overhaul of how CCPs are supervised. As part of the proposed changes, known as EMIR 2.2, those third-country CCPs deemed to be of significant systemic importance could be required to relocate to the EU as a last resort.
ISDA believes a location policy presents serious risks, and could have implications for effective coordination and cooperation between global regulators. A better outcome would be to develop a model of supervisory cooperation that enables EU supervisors to exercise appropriate and proportionate oversight of CCPs that provide clearing services in the EU.
This paper explores how enhanced supervisory cooperation might work in practice.
It also examines the risks involved in migrating third-country CCP portfolios to the EU. ISDA’s analysis finds all of the suggested methods for migration have significant weaknesses, and could lead to higher costs and operational disruption for market participants.
Read the full paper by opening the attached PDF.
Documents (1) for The Case for CCP Supervisory Cooperation
Latest
ISDA In Review – December 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in December 2025.
Response to EC on Market Risk Prudential Framework
On January 6, ISDA, the Association for Financial Markets in Europe (AFME) and the Institute of International Finance (IIF) submitted a joint response to the European Commission’s (EC) targeted consultation on the application of the market risk prudential framework. ISDA,...
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.
Response on CCP Participation Requirements
On December 24, ISDA responded to a consultation from the European Securities and Markets Authority (ESMA) on central counterparty (CCP) participation requirements. Participation requirements for CCPs are vital for safe and efficient clearing markets, and ISDA broadly supports ESMA’s consultation...
