ISDA, FIA, the Global Financial Markets Association (GFMA), the Commodity Markets Council (CMC) and the Commodity Markets Council Europe (CMCE), have responded to the International Organization of Securities Commissions’ (IOSCO) consultation report on best practices for over-the-counter (OTC) commodity derivatives position reporting.

The associations support IOSCO’s objectives to enhance market integrity, orderly trading and resilience in OTC commodity derivatives markets, but emphasize that these goals should be achieved through better use of existing data and stronger cross-border regulatory cooperation, rather than introducing new reporting requirements. The response strongly opposes proposals that could lead to mandatory or systematic OTC position reporting to exchanges or additional reporting layers, warning these would be duplicative, burdensome and potentially harmful to market functioning. Instead, it advocates for a targeted, risk-based approach, where exchanges can request specific OTC data on an ad hoc basis when justified, while broader oversight and intervention should remain with public authorities.