The EMIR REFIT will result in an expansion of the scope of AIFs that are considered to be a “financial counterparty” for the purposes of EMIR. ISDA have prepared an explanatory note to provide a high-level, factual overview of the effect of these changes, including the extent to which these changes might impact upon non-EU based alternative investment funds.

The note is available in both English and Japanese.

Update: The note was updated on 7th June 2019 to take account of publication of the EMIR REFIT Regulation in the Official Journal of the European Union on 28th May 2019.