On September 8, ISDA responded to consultation by the European Securities and Markets Authority (ESMA) on a draft regulatory technical standard on clearing fees and associated costs (article 7c(4) of the European Market Infrastructure Regulation (EMIR)). In the response, ISDA highlights that clearing service providers are already subject to existing disclosures to clients under the Markets in Financial Instruments Directive (MIFID) and articles 4(3a) and 38 of EMIR. ISDA proposes that clearing service providers should be able to meet the new requirements under article 7c by referring to existing disclosures. If there are any perceived gaps, ESMA should consider specific, targeted changes that will introduce meaningful benefits for clients rather than the proposed approach that leads to multiple overlapping disclosure requirements. ISDA also asks for an appropriate implementation period to give firms sufficient times to adapt their disclosures.