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
September 2, 2014
ISDA response to ACER consultation on reporting under the REMIT
On September 2, ISDA responded to the public consultation by the European Agency for the Cooperation of Energy Regulators (ACER) Transaction Reporting User Manual (TRUM) and Registered Reporting Mechanism (RRM) Requirements for transaction reporting under the regulation on Energy Market Integrity and Transparency (REMIT) which was launched in early August. The response addresses the definition of a market participant particularly in the case of clearing flows; the obligations on clearing broker and executing broker as they execute transactions for their clients and on their own behalf; availability of execution data under Markets in Financial instruments directive (MiFID) for the purpose of the REMIT reporting; timeline for implementation and back loading/back reporting of transactions.
20140902_REMIT_Consultation _ISDA-FIAE_Response.pdf
August 18, 2014
ISDA/FIA response to the ESMA CP on clearing obligation for interest rate derivatives
On August 18, ISDA and the Futures Industry Association (FIA) responded to the European Securities and Markets Authority (ESMA) clearing obligation consultation on interest rate derivatives. Key issues in the response include the application of the frontloading requirement, phase-in periods and counterparty categorisation.
ISDA_FIA_Europe_CO_CP Response1.pdf
July 31, 2014
JAC response to the ESMA CP on MiFID II/MiFIR
On July 31, the Joint Associations Committee on Retail Structured Products (JAC) responded to the ESMA consultation paper on MiFID II/MiFIR. This response addresses questions from the consultation that are specific to retail structured products; it was submitted alongside the ISDA response to the ESMA CP & DP addressing other questions from the ESMA consultation.
JAC MiFIR response.pdf
July 31, 2014
ISDA response to the ESMA DP and CP on MiFID II/MiFIR
On July 31, ISDA responded to the ESMA discussion paper and consultation paper on MiFID II/MiFIR. The executive summary signposts the key issues which include our recommendations on the assessment of liquidity, commodity derivatives markets, transaction reporting, systematic internalisers and indirect clearing.
ISDA MiFID CP Submission.pdf ISDA MiFID DP Submission.pdf
July 2, 2014
ISDA comment paper on EU bank structural reform proposal
ISDA has submitted a comment paper to EU decision-makers on the EC proposal for a Regulation on Bank Structure. ISDA largely limits its comments to proposed provisions most relevant to OTC derivatives.
Final  Version  ISDA comments EC Bank Structure proposal 020714.pdf
May 30, 2014
ISDA/AFME response to ESMA consultation on draft RTS on the revised Transparency Directive
On May 30, ISDA and AFME responded to the ESMA consultation paper Draft Regulatory Technical Standards on major shareholdings and indicative list of financial instruments subject to notification requirements under the revised Transparency Directive. The response highlights positive developments including the aggregation principle, which allows the inclusion of a break down by type of financial instrument (i.e. distinction between cash-settled and physically-settled derivatives) in notifications. The exemptions from notifications for market-making activities (under Article 9.5) and trading books (under Article 9.6) are also positive developments.
March 14, 2014
Response to Irish Finance Ministry consultation on EMIR implementation
On March 14, in cooperation with the Irish Debt Securities Association (IDSA), ISDA responded to the Irish Department of Finance consultation on member state discretions in the European Market Infrastructure Regulation (EMIR) No 648/2012. The response highlights concerns about a number of aspects of Irish implementation indicated in the consultation paper.
IDSA _ ISDA Joint EMIR Consultation Response.pdf
January 27, 2014
ISDA response to ESMA Level 2 MAR consultation
On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) discussion paper on measures for implementation of the rules on market abuse and insider dealing under the Market Abuse Regulation (MAR). The letter highlights that any Level 2 legislation should not go beyond the mandate provided by the regulation and should avoid over prescriptive requirements. Implementing measures should also take into account the specificities of different instruments and market participants, while ensuring a level playing field. In particular, ISDA asked for clarification of rules on market soundings, indicators of market manipulation and public disclosure of inside information and delays.
January 24, 2014
ISDA response to IOSCO consultation on the implementation of Oil Price Reporting Agencies (PRA) principles
On January 24, ISDA submitted a response to the International Organization of Securities Commissions (IOSCO) consultation on the implementation of PRA principles. ISDA supports the implementation of the PRA principles and recognises they identify the specificities of oil markets. Accordingly, ISDA does not support alignment of these principles with the IOSCO general principles for financial benchmarks.
October 18, 2013
JAC Response to the Joint Forum Consultative Document: Point of Sale disclosure in the insurance, banking and securities sector.
On October 18, the Joint Associations Committee on Retail Structured Products (JAC) responded to the Joint Forum Consultative Document: Point of Sale disclosure in the insurance, banking and securities sector. The consultation considers whether the current different regulatory approaches to Point of Sale disclosure need to be further aligned, so that consumers across all three financial sectors receive adequate product disclosure at the point of sale.
JAC Reponse to the Joint Forum Consultative document - October 2013.pdf