On June 16, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on the new clearing threshold (CT) regime. The new CT regime, based on uncleared positions, was introduced in the context of the European Market Infrastructure Regulation (EMIR 3). In the response, ISDA comments on the data analysis provided by ESMA, the interaction with the active account requirements, in particular condition 2 of EMIR 3 Article 7a(1), and proposes an implementation approach suitable for financial and non-financial counterparties, in line with the European Union’s broader simplification and burden reduction agenda. In terms of next steps, ESMA will take into account the feedback received before sending final regulatory technical standards to the European Commission.