In the paper Targeted consultation on the review of the central clearing framework in the EU from February 2022, one of the measures proposed for consideration by the European Commission (EC) was the requirement for an “active account” (ie the requirement to “maintain[…] an active account with an EU central counterparty (CCP) for the products that are available inside and outside the EU”). We understand that such a measure would require all, or a subset of, EU clearing participants to have an account at an EU CCP or a tier-1 CCP in addition to, or as an alternative to, an account at a tier-two third-country CCP.
We accept that having viable options is always good risk management, but note however that this is a tool that could, depending on how it is designed, add costs and risks for EU clearing participants (be they clearing members or clients).
As we understand that this proposal is under serious consideration by the EC, we provide analysis as to the potential consequences of different design choices.
We look at three policy options:
- Policy Option 1: No active accounts
- Policy Option 2: Active accounts without a target minimum level of activity
- Policy Option 3: Active accounts with qualitative and quantitative usage requirements – minimum activity levels
For each policy option we analyze the impact on market participants and how the policy option could be operationalized and supervised.
We also would like to refer to our paper A Roadmap to Make European Clearing More Attractive for proposals on how to make clearing in the EU more attractive without disadvantaging EU firms.
Documents (1) for Technical Paper on Active Accounts
Latest
Steps to a Vibrant Derivatives Market: SOM Remarks
Steps to a Vibrant and Resilient Derivatives Market December 4, 2025 Remarks at the Mediterranean Partnership of Securities Regulators Scott O’Malia ISDA Chief Executive Officer Good afternoon and thank you to the Mediterranean Partnership of Securities Regulators (MPSR) for...
ISDA Response to BoE on Gilt Market Resilience
On November 28, ISDA responded to the Bank of England’s discussion paper on gilt market resilience. ISDA encourages the Bank of England, before introducing any significant policy changes that would affect the functioning of the gilt repo market, to consider...
Addressing Termination Troubles
When Enron announced a shock $618 million loss on October 16, 2001, it took a further 47 days until it filed for bankruptcy. For Bear Stearns, it took 266 days between its bailout of a structured credit fund run by...
ISDA In Review – November 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in November 2025.
