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Status of Netting Legislation

Legal
Financial Law Reform
2  min.read

(Last Updated: August 22, 2025)

Please note: For further detail regarding the status of netting legislation, please see Appendix D of the 2018 Model Netting act, which can be accessed here.

ISDA, through its various regional Committees, actively promotes netting legislation on a global basis. ISDA is apprised of netting legislation developments through these regional Committees and this list represents those jurisdictions where members have informed ISDA that netting legislation has been adopted. However, this list does not purport to be a comprehensive summary of all jurisdictions globally that may have adopted netting legislation.

 

COUNTRY NETTING LEGISLATION
Andorra Adopted
Anguilla Adopted
Argentina Adopted
Armenia Adopted
Australia Adopted
Austria Adopted
Azerbaijan Under Consideration
Bahrain Adopted
Belgium Adopted
Belize Adopted
Botswana Adopted
Brazil Adopted
British Virgin Islands Adopted
Bulgaria Adopted
Cambodia Under Consideration
Canada Adopted
Channel Islands – Jersey Adopted
Chile Adopted
China Adopted
Colombia Adopted
Costa Rica Adopted
Croatia Adopted
Cyprus Adopted
Czech Republic Adopted
Denmark Adopted
Dominican Republic Under Consideration
Egypt Under Consideration
Estonia Adopted
Ethiopia Under Consideration
Finland Adopted
France Adopted
Georgia Adopted
Germany Adopted
Ghana Adopted
Greece Adopted
Hungary Adopted
India Adopted
Indonesia Adopted
Ireland Adopted
Israel Adopted
Italy Adopted
Japan Adopted
Kazakhstan Adopted
Kosovo Under Consideration
Latvia Adopted
Liechtenstein Adopted
Lithuania Adopted
Luxembourg Adopted
Malaysia Adopted
Malta Adopted
Marshall Islands Adopted
Mauritania Adopted
Mauritius Adopted
Mexico Adopted
Morocco Under Consideration
New Zealand Adopted
Nigeria Adopted
Norway Adopted
Pakistan Under Consideration
Panama Under Consideration
Peru Adopted
Poland Adopted
Portugal Adopted
Qatar Adopted (QFC regime)
Romania Adopted
Russia Adopted
Rwanda Adopted
Saudi Arabia Adopted
Serbia Adopted
Seychelles Under Consideration
Slovakia Adopted
Slovenia Adopted
South Africa Adopted
South Korea Adopted
Spain Adopted
Sri Lanka Under Consideration
Sweden Adopted
Switzerland Adopted
Tunisia Under Consideration
Uganda Adopted
Ukraine Adopted
United Arab Emirates Adopted (in the DIFC, ADGM free zones and federal law level)
United Kingdom Adopted *
United States Adopted
Uruguay Adopted
Zambia Adopted
Zimbabwe Adopted

 

* ISDA provides legal opinions for the laws of England & Wales as well as Scotland. As of February 21, 2009, the UK Banking Act introduced a new insolvency law for all UK jurisdictions providing for a special resolution regime for banks and building societies. This includes specific netting legislation for transactions with such counterparties. With regard to most other counterparties the previous regime remains in place. In England, the enforceability of netting is widely accepted without the need for specific statutory recognition. Please refer to the ISDA netting opinions on English and Scots law respectively. For other jurisdictions without specific netting statutes, e.g Turkey, Netherlands, Hong Kong, please refer to the relevant ISDA netting opinions.

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