In November 2021, the European Securities and Markets Authority (ESMA) published a consultation on its report on highly liquid financial instruments with regards to the investment policy of central counterparties. In this consultation, ESMA reviews whether the current, fairly restrictive list of investment options for central counterparties (CCPs) should be extended. The report contains a very thorough analysis of regulation and CCP practices in other jurisdictions and proposes some extension of the range of investments available to a CCP, for instance debt issued by the EU but also consults about including corporate debt. On money market funds, ESMA is more careful and proposes for now not to allow these funds.
ISDA members are very supportive of some of the extension of investments available to the CCP and propose to be less prescriptive but to give the CCP and its governance forums including supervisors more leeway. In the response, we also support the inclusion of public debt constant net asset value money market funds, which had significant inflows during the crisis in 2020.
Please find below the ISDA response.
Documents (1) for ISDA Responds to ESMA on Eligible CCP Investments
Latest
Response to MAS on Treatment of Crypto Assets
On May 15, ISDA and the Asia Securities Industry and Financial Markets Association submitted a joint response to the Monetary Authority of Singapore’s (MAS) consultation, published in April 2026, on the prudential treatment of crypto assets on permissionless blockchains, welcoming MAS’s more...
Joint Response to EC on Market Risk Delegated Act
ISDA and the Association for Financial Markets in Europe (AFME) have responded to the European Commission’s (EC) consultation on the draft legal text of the upcoming market risk delegated act. The associations welcome the ongoing efforts to address the implementation...
ISDA/ASIFMA/GFXD Letter to RBI on INR-Denominated FX Derivatives Reporting
On March 9, 2026, ISDA, ASIFMA, and GFXD submitted a joint letter to the Reserve Bank of India (RBI) in response to the RBI’s Reporting Instructions for Authorised Dealer (AD) Category – I Banks draft directions to mandate the reporting...
IRD Trading Activity FY 2025 and Q4 2025
This report analyzes interest rate derivatives (IRD) trading activity reported in Europe. The analysis is based on transactions publicly reported by 30 European approved publication arrangements (APAs) and trading venues (TVs). Key highlights for the full year 2025 include: European...