ISDA Response to EMIR Active Account Consultation

On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on the active account requirement (AAR) introduced under the revised European Market Infrastructure Regulation (EMIR 3.0). In the response, ISDA highlighted significant concerns about the proposed reporting regime to monitor compliance with the AAR. The proposal seems to go beyond what is necessary to monitor compliance and is inconsistent with the EU’s recent commitment to reduce administrative and reporting burdens. The response also highlights that some aspects of the operational requirements – in particular, stress testing – are not clear. However, the response welcome the fact that the proposed calibration of interest rate swaps denominated in Polish zloty for the representativeness requirement recognizes that liquidity at EU central counterparties is extremely limited.

Documents (1) for ISDA Response to EMIR Active Account Consultation

Creating Value - IQ June 2025

Ever since its establishment 40 years ago, ISDA has worked to enhance the safety and efficiency of derivatives markets. That has motivated everything we do – from the development of standard documentation and the rollout of new digital solutions to...

Paper on EC’s Sustainability Omnibus Proposal

On June 9, ISDA published a position paper setting out its views on the European Commission’s (EC) Sustainability Omnibus Package. In the paper, ISDA urges European authorities to: Ensure a proportionate, harmonized and symmetrical approach to the use of derivatives...

Bulk Adherence Upload Page

Please download the attached Excel worksheet and fill out a separate row for each adherence. Then select and upload your completed file using the buttons below. If any errors are found, please correct and re-upload. Please allow the process time...