ISDA Submits Recommendations to Simplify EU Regulation and Enhance Legislative Process

On March 9, ISDA submitted a paper to the European Commission setting out focused proposals to improve the functioning of the EU regulatory framework for derivatives. The paper comprises eight targeted recommendations to simplify selected Level 1 provisions in a way that preserves high regulatory standards while delivering meaningful reductions in operational complexity and compliance costs. These adjustments would enhance the EU’s attractiveness as a location for derivatives activity and reinforce its capacity to support investment and competitiveness.

The paper also outlines two horizontal recommendations intended to improve the legislative process. These relate, first, to the sequencing of Level 1 and Level 2 measures and, second, to the introduction of a time-limited mechanism allowing for the temporary suspension of specific requirements where warranted by market conditions or implementation challenges.

Overall, ISDA believes these proposals would contribute constructively to the EU’s broader objectives of competitiveness, well‑functioning capital markets and proportionate regulation.

Documents (1) for ISDA Submits Recommendations to Simplify EU Regulation and Enhance Legislative Process

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...