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
June 12, 2017
ISDA sends letter to EC on CCP location policy
ISDA sent a letter to the European Commission on June 8, which contains the results of an industry survey on the impact of a European CCP location policy. The survey finds that a location policy for euro clearing in the eurozone would result in significantly higher initial margin requirements for clearing firms because of a loss of netting efficiencies
ISDA FINAL response to EC Communication 8 June 2017.pdf
May 4, 2017
ISDA and FIA comment on information disclosures for commodity derivatives
ISDA and FIA have submitted a joint response to the FCA Quarterly Consultation Paper 17/6. The response focused on Chapter 3 of the consultation paper, which deals with proposed changes to the Financial Conduct Authority Market Conduct source book relating to European Securities and Markets Authority guidelines on commodity derivatives.
FIA - ISDA Response to FCA Quarterly CP 17_6 - 28 April 17.pdf
January 12, 2017
ISDA/FIA respond to ESMA consultation on package orders
On January 3, 2017, ISDA and FIA responded to the European Securities and Markets Authority's (ESMA) consultation on package orders for which there is a liquid market. The consultation paper proposed a methodology by which package orders would be considered liquid under the revised Markets in Financial Instruments Directive (MIFID II).
Response to ESMA Package Orders CP.pdf
December 2, 2016
Response to ESMA consultation paper on Benchmarks RTS
On December 2, ISDA, the FIA and SIFMA jointly responded to a consultation paper by the European Securities and Markets Authority on regulatory technical standards (RTS) for the Benchmarks Regulation. The response requested a number of clarifications including on the third-country regime, transitional provisions and scope.
November 21, 2016
Response to ESMA discussion paper on the trading obligation
On November 21, ISDA responded to a September 20 discussion paper by the European Securities and Markets Authority on how to implement the trading obligation for derivatives under the Markets in Financial Instruments Regulation. The discussion paper included preliminary analysis of some classes of derivatives that could become subject to the trading obligation.
ISDA RESPONSE - 21 Nov 2016.pdf
September 16, 2016
ISDA response to ESMA consultation on clearing obligation phase-in for Category 3 parties
On September 5, ISDA submitted a response to the European Securities and Markets Authority (ESMA) consultation paper on a proposal to amend the phase-in period of the clearing obligation for financial counterparties with a limited volume of activity.
ISDA ESMA CAT 3 CP FINAL [050916].pdf
May 23, 2016
Joint ISDA/FIA response to ESMA consultation on MAR guidelines for commodity markets
On May 20, 2016, ISDA and the FIA submitted a response to the consultation paper by the European Securities and Markets Authority aimed at producing guidelines on information expected or required to be disclosed on commodity derivatives markets or related spot markets under the Market Abuse Regulation.
Joint FIA and ISDA Consultation-Response (20 May 2016).pdf
May 13, 2016
ISDA letter to EC on margin RTS drafted by European supervisory authorities
On May 10, 2016, ISDA submitted a letter to the European Commission on the requirements for settlement timing for variation margin under the non-cleared derivatives margin regulatory technical standards drafted by the European supervisory authorities.
ISDA VM Margin letter to EC 090516final.pdf
May 3, 2016
ISDA letter to European Commission on Margin RTS
On April 29, 2016, ISDA submitted a letter to the European Commission on the Margin RTS drafted by the European Supervisory Authorities. The letter covers a range of issues, but does not cover variation margin settlement timing, which will be addressed in a separate letter.
ISDA - Margin RTS - Letter to EC 280416.pdf
April 7, 2016
ISDA responds to the EC’s consultation on European financial legislation impact
When publishing its capital markets union proposal in September 2015, the European Commission (EC) launched a consultation on the cumulative impact assessment of European financial legislation in order to identify the areas where adjustments would help growth and jobs in the European Union. ISDA submitted a response to this cumulative impact assessment that predominantly focuses on the following three topics: a) capital rules; b) market transparency rules (pre-trade public transparency of derivatives markets under the Europe’s revised Markets in Financial Instruments Directive; and c) review of the European Market Infrastructure Regulation, which addresses reporting to trade repositories, central clearing and margining of derivatives. The introduction of this response aims to strongly support and demonstrate the benefits of derivatives markets for the economic growth. This response will serve as a reference for ISDA’s advocacy efforts in the coming months in Europe.