On October 21, ISDA and nine other trade associations – the Alternative Investment Management Association, the European Association of Co-operative Banks, the European Association of Corporate Treasurers, the European Banking Federation, the European Fund and Asset Management Association, the European Principal Traders Association, the European Venues and Intermediaries Association, FIA and the Managed Funds Association – wrote to the European Commission (EC) to ask that it provide guidance that counterparties are not required to report information on clearing activity on third-country central counterparties (CCPs) under Article 7d of the European Market Infrastructure Regulation (EMIR 3.0) until the corresponding regulatory technical standards and implementing technical standards are applicable.

Requiring firms to report their activity on third-country CCPs before the corresponding technical standards have been finalized would be a complex operational undertaking that would incur substantial costs and would not yield meaningful improvements in transparency for regulators. Pausing this reporting requirement until the technical standards become applicable will avoid firms effectively having to implement the requirements twice and will align more closely with the EC’s objective to simplify and reduce the reporting burden.