Technical Paper on Active Accounts

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.

Episode 59: Reducing Burdens

As she nears the end of her term as chair of the European Securities and Markets Authority, Verena Ross joins The Swap to discuss progress in simplifying and reducing the burden of EU financial regulation, including transaction reporting. Please view...

CDS Market Dynamics: Record 2025

Global credit default swap (CDS) market activity reached a record $41.8 trillion in 2025, surpassing the previous peak of $38.7 trillion in 2022. Index CDS drove the increase, accounting for 93.3% of total activity and reaching a record $39.0 trillion....

ISDA Letter to BCBS on RMA Models

On July 24, ISDA wrote to the Basel Committee on Banking Supervision (BCBS) to request guidance on how the proposed Risk Mitigation Accounting (RMA) model under International Financial Reporting Standard (IFRS) 9/IFRS 7 should be treated for prudential regulatory capital...