Benchmark Fallbacks

Interbank Offered Rates (IBORs), a series of interest rate benchmarks, are undergoing a period of change as regulators and industry groups have recommended that firms transition away from the London Interbank Offered Rate (LIBOR) and other IBORs and prepare to replace them with alternative, overnight Risk Free Rates (RFRs). These RFRs, including SOFR (USD), €STR (EUR) and SONIA (GBP), are typically administered and published by major central banks worldwide. Transitioning to the RFRs will be a demanding and complex process for the industry as RFRs are structurally different from IBORs. They are overnight rates and exhibit different liquidity characteristics and supply/demand issues than IBORs.

To address the risk that one or more IBORs are discontinued while market participants continue to have exposure to that rate, counterparties are encouraged to agree to contractual fallback provisions that would provide for adjusted versions of the RFRs as replacement rates.

Due to the fundamental differences in the nature of IBORs and the RFRs, key adjustments are necessary if fallbacks to RFRs are to take effect in contracts that were originally negotiated to reference the IBORs. ISDA ran public consultations to finalize the adjustment methodologies and subsequently issued a tender invitation for a vendor to perform and distribute these necessary adjustments.

These consultations yielded industry consensus, and more information about them can be found below.

Bloomberg Test Data for IBOR Fallbacks

Bloomberg Rulebook for IBOR Fallback Methodology

2020 Pre-Cessation Fallback Consultation

IBOR Fallback Rate Adjustments FAQs – Updated May 4, 2020

Results – December 2019 Benchmark Fallbacks Supplemental Consultation

December 2019 Benchmark Fallbacks Supplemental Consultation

Results – September 2019 Consultation on Final Parameters

September 2019 Consultation on Final Parameters

Results – May 2019 Supplemental Consultation

Results – May 2019 Consultation on Pre-Cessation Issues

May 2019 Benchmark Fallbacks Consultations

Results – 2018 Benchmark Fallbacks Consultation

2018 Benchmark Fallbacks Consultation

 

Target Timing for Fallback Implementation
Publication of Bloomberg indicative fallback rates Middle of 2020 (before publication of amendments to the 2006 ISDA Definitions and related protocol)
Publication of amendments to the 2006 ISDA Definitions and related protocol July 2020
Effectiveness of amendments to the 2006 ISDA Definitions and related protocol November 2020 (or 4 months after publication)

 

ISDA Comments: OSC Call for Feedback

On June 26, 2026, ISDA submitted comments to the Ontario Securities Commission’s (OSC) consultation on facilitating access to its regulatory framework and reducing burden for capital markets participants by publishing a machine-readable dataset of regulatory instruments. The comments are supportive...

ISDA Comments on EP's MISP Draft Reports

On July 15, ISDA shared comments with policymakers in the European Union on the European Parliament’s (EP) draft reports by Member of the European Parliament (MEP) Markus Ferber and MEP Eero Heinäluoma on the Market Integration and Supervision Package (MISP)....

Building Markets, Creating Opportunity

Deep and liquid derivatives markets are fundamental to the development of well-functioning financial markets and healthy economies. They support lending, investment and financial stability, creating the certainty needed for economic growth. But strong derivatives markets do not emerge by chance....

Key Trends in OTC Derivatives Market H2 2025

The latest data from the Bank for International Settlements over-the-counter (OTC) derivatives statistics shows an increase in notional outstanding of OTC derivatives during the second half of 2025 compared to the same period in 2024. Notional outstanding rose across all...