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
October 10, 2017
ISDA Publishes Letter on EC’s CCP Oversight Proposals
ISDA has submitted a letter on the European Commission’s proposed regulation on the authorization and recognition of third-country central counterparties (CCPs). The letter highlights a number of risks presented by a location policy, such as the geographical fragmentation of markets and distortions in competition, as well as material adverse impacts on the reduction of systemic risk, added costs, and reduced market liquidity and efficiency.
September 4, 2017
Joint ISDA/AFME response to the evaluation of the Short Selling Regulation
On September 4, 2017, ISDA and AFME responded to the European Securities and Markets Authority’s (ESMA) consultation on the evaluation of the Short Selling Regulation. We renewed our call for the market-making exemption to be made available to those making a market in over-the-counter derivatives.
AFME-ISDA-response-letter-to-ESMA-CP-on-SSR-Final Version Clean.pdf
August 21, 2017
Brexit – CCP Location and Legal Uncertainty
ISDA has published the first in a series of whitepapers that will consider issues relating to Brexit, and the potential impact on the derivatives market.
Brexit paper 1 FINAL1.pdf
July 24, 2017
Industry associations support European Commission’s draft Delegated Acts under the EU Benchmarks Regulation
ISDA, in partnership with FIA and GFMA, expressed its support for the European Commission’s draft Delegated Acts under the EU Benchmarks Regulation
GFMA_FIA_ISDA Draft Response to EC Consultation on Draft DAs 20170720 FINAL.pdf
July 18, 2017
ISDA comment on the EMIR REFIT proposal
ISDA expressed it support the European Commission to amend the European Market Infrastructure Regulation (EMIR) and proposed further edits to enhance the framework by reducing costs and complexity for end-users.
ISDA-comments-on-EMIR-Refit-proposal - Final 18 July 2017.pdf
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