ISDA has submitted to the European Securities and Markets Authority (ESMA) an analysis of the costs of regulatory reporting, which proposes where savings can be made most effectively.
This document supplements the recent response submitted by ISDA, the Association for Financial Markets in Europe, FIA and the Global FX Division of the Global Financial Markets Association to ESMA’s call for evidence on a comprehensive approach for the simplification of financial transaction reporting. The new analysis and proposals reflected in this supplementary document were developed based on member feedback to a questionnaire carried out by ISDA. All answers have been anonymized and aggregated.
The responses supported many of the arguments put forward in the original response, with the most impactful cost saving identified as the delineation by instrument (OTC derivatives under the European Market Infrastructure Regulation and exchange-traded derivatives under the Markets in Financial Instruments Regulation) as proposed under Option 1a. There was also strong support for single-sided reporting and the removal of pairing and matching requirements.
ISDA developed this analysis for ESMA’s consideration in drafting the final report following the call for evidence.
Documents (3) for ISDA Submits Supplementary Analysis to ESMA on Reporting Costs
- ESMA CASR ISDA cost questionnaire analysis Final 100825(pdf) will open in a new tab or window
- ESMA CASR ISDA Appendix 2 cost questionnaire aggregated answers(xlsx) will open in a new tab or window
- ESMA CASR ISDA Appendix 1 Questionnaire on the cost of compliance with EU reporting requirements(pdf) will open in a new tab or window
Latest
ISDA Publishes Updated ISDA SIMM Governance
ISDA has published an updated version of the ISDA SIMM® Governance Framework, which sets out the principles under which the ISDA Standard Initial Margin Model® operates and the process through which it will be reviewed and amended on a consistent...
ISDA Response to PRA IMA Consultation
On September 18, ISDA, the Association for Financial Markets in Europe, the Institute of International Finance and UK Finance submitted a joint response to the UK Prudential Regulation Authority consultation on adjustments to the internal model approach (IMA) for the...
Calibration Test – IQ September 2026
Calibrating capital requirements is a highly complex undertaking and getting it wrong can have serious consequences. Too much lenience might lead to banks holding insufficient capital to mitigate their risks. But excess conservatism can put balance sheets under strain, forcing...
US Treasury Repo Clearing Indicators July 2026
The ISDA-Actrix US Treasury Repo Market Clearing Indicators illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation in central clearing, a key objective of the Securities...