On April 20, ISDA submitted a response to the European Securities and Markets Authority (ESMA) consultation paper on a draft regulatory technical standard (RTS) for the post-trade risk reduction (PTRR) exemption from the derivatives clearing obligation under Article 4b of the European Market Infrastructure Regulation (EMIR).
In the response, ISDA provides drafting suggestions for the proposed RTS and makes the following comments:
- On the description of eligible PTRR services, ISDA emphasizes the importance of keeping principles-based definitions to allow for ongoing innovation;
- On safeguards to avoid circumvention of the clearing obligation, ISDA notes that existing requirements to benefit from the exemption, in terms of risk reduction, market risk neutrality and existing reporting under Article 9 of EMIR already act as de facto safeguards, so there is no need for any specific limitations to be added;
- On requirements for PTRR service providers, ISDA suggests that reporting and record-keeping requirements should avoid duplication and leverage the exercise performance report;
- On governance, conflicts of interest and compliance requirements, PTRR service providers are already subject to requirements on these matters as investment firms under the Markets in Financial Instruments Directive.
Documents (1) for ISDA Responds to ESMA on PTRR Clearing Exemption
Latest
Efficiency is Vital to Delivering Resilience
With less than three months to go until implementation of US Treasury clearing begins at the end of this year, it’s critical that the mandate is safely implemented without compromising market efficiency. This represents a huge change in market structure,...
ISDA In Review – September 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in September 2026.
ISDA Digital Assets Forum Opening Remarks
ISDA Digital Assets Forum Washington, DC October 6, 2026 Opening Remarks Scott O’Malia, CEO, ISDA Good morning, and a very warm welcome to the ISDA Digital Assets Forum. Thanks for joining us today, and a special thank you to...
Assessing Tokenized MMFs as Eligible Collateral
Distributed ledger technology and digital assets have matured from their early stages to solutions capable of addressing longstanding inefficiencies in collateral management. Tokenized money market funds (TMMFs) represent a particularly promising area for the application of this technology, combining the...
