In July 2021, ISDA responded to a Bank of England (BoE) consultation on the inclusion of transactions referencing certain risk-free rates (RFRs) into the clearing obligation. In addition, the BoE released a supplementary consultation on the inclusion of swaps referencing TONA in September, which ISDA responded to on October 26, 2021.
ISDA members support the BoE’s proposal to adapt the derivatives clearing obligation under the UK’s European Market Infrastructure Regulation in the context of interest rate benchmark reform. ISDA members acknowledge the benefits of central clearing, as demonstrated by the current clearing rates for RFR swaps. Introducing a clearing obligation for these products could be a helpful tool to avoid liquidity fragmentation.
However, transactions stemming from post-trade risk-reduction exercises should be exempt from the clearing obligation to enable market participants to manage the risks in their non-cleared portfolios.
While not strictly in scope of this consultation, the effect of a clearing obligation for over-the-counter RFR-linked derivatives on the derivatives trading obligation (DTO) should be kept in mind. This should be carefully and independently analyzed, as it could have a detrimental impact on the market. Transactions not subject to the clearing obligation, such as IBOR swaps, should be removed from the scope of the DTO.
ISDA members also support a clearing obligation for TONA swaps, but recommend sufficient time to enact all changes to systems (internal and external) and control frameworks. ISDA members would welcome confirmation that the BoE or other UK authorities will not use their supervisory power if insufficient notice is provided between the BoE final policy statement and the effective date of the rule.
Documents (2) for ISDA Responds to BoE Consultation on RFR Clearing Obligation
Latest
ISDA, FIA and SIFMA Letter on Sunset of Swaps LTR Rules (Part 20)
On May 20, 2026, ISDA, FIA and SIFMA submitted a joint letter to U.S. Commodity Futures Trading Commission (CFTC) to request the CFTC to sunset large trader reporting rules (LTR) rules for physical commodity swaps pursuant to Regulation 20.9.
ISDA-SIFMA Letter – CFTC-SEC Harmonization
On May 19, 2026, ISDA and SIFMA submitted a joint letter to the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) on SEC and CFTC harmonization, as part of the agencies’ Joint Harmonization Initiative which...
ISDA AGM Studio: Jim Byrd, RBC Capital Markets
Jim Byrd, global head, macro products, at RBC Capital Markets, joins the ISDA AGM studio to discuss the main risks and opportunities in the current trading environment and what needs to be done to avoid liquidity squeezes during periods of...
ISDA AGM Studio: Michelle Beck, FCA
Michelle Beck, director for wholesale buy‑side oversight at the Financial Conduct Authority, speaks with ISDA’s global head of public policy, Steven Kennedy, about the regulatory approach to systemic risk in non‑bank financial intermediation after a panel discussion on how robust...
