Europe

This section catalogues ISDA’s work across the European region, highlighting public policy efforts.

Click to visit the Eurozone Contingency Planning  page.

Click to visit the EMIR Focus page and MiFID Focus page.


DateTitle / DescriptionDocuments
August 19, 2015
Response to the European Commission EMIR Review CP
On August 13, ISDA responded to the European Commission’s consultation on the EMIR Review. ISDA highlighted a number of priority issues in its response including advocating for a move to a single-sided reporting regime and the removal of the frontloading obligation.
EMIR REVIEW RESPONSE FINAL [190815].pdf
August 12, 2015
ISDA and four other associations submit letter on EMIR Article 13 Equivalence to EC
On June 22, the International Swaps and Derivatives Association, the Investment Association, FIA Europe, the Managed Funds Association and the Alternative Investment Management Association submitted a letter to the European Commission regarding the importance of EMIR Article 13 and MiFIR Article 33 equivalence in the context of clearing, margin, reporting and trading requirements for derivatives transactions. The letter highlighted the potential negative impact on access to non-European Union (EU) markets by EU institutions that could result in the absence of equivalence decisions.
ISDA-FIA Europe-MFA-IA-AIMA Equivalence Letter Final sig.pdf
August 12, 2015
Response to the ESMA clearing obligation consultation for EEA rates derivatives
On July 15, ISDA, FIA Europe and the Investment Association jointly responded to the European Securities and Markets Authority’s consultation on draft regulatory technical standards for the mandatory clearing of EEA interest rate derivatives.
ISDA-FIA Europe-Investment Association CO EEA Rates FINAL [150715].pdf
June 1, 2015
JAC responds to FCA thematic review on product development and governance of structured products
On March 5, 2015, the UK Financial Conduct Authority (FCA) published a thematic review on the product development and governance of structured products. Firms need to ensure they design products that have a reasonable prospect of delivering economic value to end clients and promote their features in a clear and balanced way. The thematic review highlights further areas that firms need to work on. Given the firms are replying in detail to the FCA, the Joint Associations Committee’s (JAC) letter focuses on high-level issues.
JAC Response to FCA Structured Products Thematic.pdf
May 15, 2015
ISDA/FIA Europe publish Capital Markets Union position paper & response to the EC Green Paper on Building a Capital Markets Union
ISDA and FIA Europe have jointly published a position paper on the EU Capital Markets Union. The paper seeks to highlight the crucial role derivatives play in capital markets. And how it necessary that derivatives reforms in Europe governing clearing, margining and trading of derivatives are calibrated to a standard that also facilitates the efficient functioning of derivatives markets, and does not introduce new risks that damage liquidity.
ISDA FIA Europe CMU Green Paper Response.pdf ISDA FIA Europe CMU Position Paper.pdf
May 14, 2015
JAC responds to EC consultation on the Prospectus Directive
On February 18, 2014, the European Commission published a consultation paper relating to the review of the Prospectus Directive. The paper sought to identify the needs of prospectus users with regards to scope, form, content, comparability, the approval process, liability and issuers. Feedback was also requested on aspects that unduly hinder access to capital markets, liability and sanctions. The Joint Associations Committee on Retail Structured Products response focuses on the questions that are of particular interest to the structured securities industry.
PDIII - JAC response letter.pdf PDIII - JAC response form.pdf
March 23, 2015
ISDA response to ESMA’S MIFID II/MIFIR Addendum
ISDA submitted its response to an addendum on the revised Markets in Financial Instruments Directive and Regulation (MIFID II/MIFIR) on March 20, in response to a consultation published by the European Securities and Markets Authority on February 18, 2015.
ISDA - Addendum - final draft - 20 March 2015.pdf
March 2, 2015
ISDA response on MIFID II/MIFIR consultation
On March 2, 2015, ISDA submitted its response to the European Securities and Markets Authority’s consultation on the revised Markets in Financial Instruments Directive (MIFID II) and Markets in Financial Instruments Regulation (MIFIR).
MiFID II CP- ISDA Final Response 02-03-2015.pdf
February 24, 2015
Public comment on the IOSCO Task Force on Cross-Border Regulation Consultation Report
ISDA appreciates the International Organization of Securities Commissions (IOSCO) Task Force on Cross-Border Regulation’s engagement with the industry throughout this consultation process. ISDA has previously submitted comments to the Task Force on a number of specific issues, and highlighted how OTC derivatives markets have been affected by a lack of effective cross-border regulatory harmonization. OTC derivatives markets have historically been the most global in nature of all financial markets, and the absence of consistency in regulatory reform is having a direct impact on these markets as a result. We appreciate the efforts of the Task Force, in this latest Consultation Report, to identify tools at a regulator’s disposal to address cross border regulation. In this letter, ISDA reiterates how cross-border regulatory harmonization could be achieved, and suggests ways in which IOSCO can reduce undesirable regulatory outcomes that threaten the efficient functioning of markets.
IOSCO Cross Border consultation response for submission.pdf
February 17, 2015
JAC response to the Discussion Paper on Key Information Documents for Packaged Retail and Insurance-based Investment Product (PRIIPs)
In November 2014 the three European Supervisory Authorities (ESAs) issued a discussion paper that set out their early thinking regarding the drafting of the Level 2 Regulatory Technical Standards (RTS) to support the EU PRIIPs Regulation (Regulation (EU) No 1286/2014). Past experience suggests that this will be an important opportunity to influence the outcome of this process. The Joint Association Committee has prepared a detailed response to the discussion paper. The JAC response covers areas of significant importance to the industry including issues such as the approaches to measuring and disclosing risk, costs and product performance in the KIID and the rules relating to review, revision and republication of the KIID. A further Discussion Paper on the more complex methodological aspects of the RTS is expected later this Spring followed by further Consultation Papers on the text of the draft RTS once this has been prepared by the ESAs.
PRIIPS Response - Feb 2015.pdf