ISDA Letter on EMIR Review

On October 3, 2022, ISDA wrote to the European Commission, the European Banking Authority, the European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority to urge them to take the opportunity while working on the revision of the European Market Infrastructure Regulation (EMIR) to remove unnecessary barriers to clearing in Europe and avoid market fragmentation. In the letter, ISDA asks for the removal of equivalence as a pre-condition to the availability of the intragroup transaction exemption from margining, clearing and credit value adjustment under the EU Capital Requirements Regulation. ISDA recommends that EMIR article 13 equivalence is revisited – in particular, the requirement that one of the relevant group entities be ‘established’ in the third-country jurisdiction concerned, so EU firms can avoid duplicative and conflicting margin, clearing and reporting requirements under EU and third-country rules. ISDA has also proposed a revision of the initial margin eligibility rules so third-country money markets funds meeting strict criteria are eligible collateral.

Documents (1) for ISDA Letter on EMIR Review

Data Integrity for Single-sided Reporting

On April 2, ISDA published a paper on why single-sided reporting does not compromise the quality and integrity of data received by supervisors. The paper addresses concerns among regulators that moving from dual-sided reporting would adversely affect the quality of...

Paper on Removal of SI Regime

On April 2, ISDA, the Association for Financial Markets in Europe (AFME) and the International Capital Market Association (ICMA) published an update to a paper, originally published in October 2025, on the practical implications of the systematic internalizer (SI) regime...

Measured Adjustments - IQ April 2026

Eighteen years on from the global financial crisis of 2008, the rollout of central clearing, margining of non-cleared derivatives trades and higher capital requirements has completely reshaped derivatives trading and risk management. But effective regulation requires regular monitoring to ensure...