On March 29, 2023, ISDA, the European Association of Corporate Treasurers, the Trade Association for the Emerging Markets, the Futures Industry Association and the Global Financial Markets Association submitted a joint response to the European Commission’s (EC) call for evidence on the review of the scope and third-country regime of the European Union (EU) Benchmarks Regulation (BMR).

The associations note that the reforms outlined in the call for evidence represent an opportunity to rebalance the BMR so it provides protection to investors on a proportionate basis in alignment with global standards, imposing the highest compliance burdens on the most systemically important benchmarks and ensuring EU investors have better visibility of the benchmarks they are permitted to use and those they are not. However, other reforms are needed to ensure end users do not face cliff-edge risks in respect of benchmarks they use that are prohibited for any reason.