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

Market Transformation – IQ May 2026

On the 250th anniversary of American independence, this year’s ISDA Annual General Meeting (AGM) was held in Boston, a city that played a prominent role in the American Revolution. In his opening remarks, ISDA chief executive Scott O’Malia drew a...

Letter to EC and ESMA on Derivatives Framework

On March 27, ISDA sent a letter to the European Commission (EC) and the European Securities and Markets Authority (ESMA) to highlight several technical issues arising from the interaction between the delegated regulation (EU) 2025/1003 on identifying reference data to...