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ISDA Response to ESMA on CCP Participation Requirements

Infrastructure
Clearing January 6, 2026
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On December 24, ISDA responded to a consultation from the European Securities and Markets Authority (ESMA) on central counterparty (CCP) participation requirements. Participation requirements for CCPs are vital for safe and efficient clearing markets, and ISDA broadly supports ESMA’s consultation and proposed regulatory technical standards, which promote fair access and clear membership criteria. While some requirements may scale with clearing member size, core standards on risk management and operational resilience should remain robust. ISDA welcomes the inclusion of sponsored models with clear responsibilities and contingency measures, as well as proposals addressing mutualization risks. However, implementation must be phased to avoid operational disruption, premature position unwinds or market instability as abrupt changes could lead to member exits and concentration risks.

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