On February 15, ISDA and the Association for Financial Markets in Europe (AFME) submitted a joint response to the UK Financial Conduct Authority’s (FCA) consultation on the reform of the UK commodity derivatives regulatory framework. The consultation sought to remove unnecessary burdens on firms and strengthen the supervision of UK commodity derivatives markets.
In the response, the associations strongly support the FCA’s proposal to apply a narrower position limits regime that is more proportionate to the risks associated with certain commodity derivatives contracts. However, the associations express concern over the proposed approaches for setting position limits and adding additional reporting obligations. They note the complex and burdensome frameworks proposed can discourage participation in UK trading venues by non-UK participants and may have a negative impact on the competitiveness of UK markets. The response also recommends a longer implementation period of at least 24 months due to the scale of the operational and technical changes required.
Documents (1) for ISDA Responds to FCA on Commodity Derivatives
Latest
ISDA Omnibus Canadian Representation Letter
On September 2, 2026, ISDA published the Omnibus Canadian Representation Letter (the “Omnibus Canadian Letter”), which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The...
ISDA-FIA Letter re CFTC-SEC X Margin/Port Margin
On August 31, ISDA and the Futures Industry Association (FIA) submitted a letter to the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC) on the agencies' Joint Request for Comment on Further Implementation of...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
Response to SEC on FICC Guaranty Fund
On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...