On July 23, 2021, ISDA and the Futures Industry Association (FIA) submitted a joint response to the European Securities and Markets Authority’s (ESMA) consultation on technical standards (draft RTS 21 and ITS 4) for commodity derivatives, following announced changes to the position limits regime as part of the revised Markets in Financial Instruments Directive’s ‘quick fix’, which will apply from February 28, 2022.
While members are largely supportive of draft RTS 21 and ITS 4 and believe they will improve the position limits regime, there are some areas of concern. These include ESMA’s proposals relating to a scenario where deliverable supply is substantially higher than open interest, and proposals relating to position management, which the associations believe would benefit greatly from increased flexibility for trading venues to avoid a substantial burden on both the venues and market participants.
Documents (1) for ISDA Response to ESMA on Technical Standards for Commodity Derivatives
Latest
The CPI Quandary
The recent US government shutdown didn’t just create weeks of political drama – it also left inflation-linked swaps dealers with a major headache: how should they determine an initial value for new trades given the US Bureau of Labor Statistics...
ISDA Response to HMT, BoE on UK CCPs
On November 18, ISDA submitted its responses to the Bank of England (BoE) consultation on ensuring the resilience of central counterparties (CCPs) and the UK Treasury’s (HMT) two draft CCP statutory instruments (SIs). These consultations form part of the update...
Doubling Down on Appropriate Trading Book Capital
Throughout ISDA’s 40th anniversary year, we’ve been reflecting on the quest for greater consistency and efficiency that underpins everything we’ve achieved since 1985. It was at the heart of the original efforts to bring greater standardization to the nascent derivatives...
Determining Initial Reference Index for New Trades
On November 25, 2025, ISDA published a Market Practice Note (MPN) to recommend a specific methodology that market participants could elect to use for the purposes of determining the Initial Reference Index for certain new inflation derivative transactions given that...