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 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.
April 6, 2016
ISDA submits joint response on ESMA’s paper on benchmarks
On March 31, ISDA, the FIA and Global Financial Markets Association submitted a response to a discussion paper by the European Securities and Markets Authority aimed at clarifying Europe’s financial benchmarks regulation. The regulation organises how financial benchmarks are produced, what obligations are applicable to their administrators and contributors, and how end users may refer to EU and non-EU benchmarks. Formal consultations on draft technical advice and technical standards are expected in the course of 2016.
Consultative response ESMA Discussion Paper Benchmarks Regulation FINAL ....pdf
March 23, 2016
Response to ESMA’s Consultation Paper on Guidelines on transaction reporting, reference data, order record keeping & clock synchronization (ESMA/2015/1909)
ISDA’s response to ESMA’s Consultation Paper on proposed Guidelines for certain data and reporting aspects of MiFIDII / MiFIR found in Regulatory Technical Standards 22, 23, 24 and 25 of the regulation.
Response_ESMA Guidelines on trans rep, ref data, ord rec keeping & clock synch_23 March 2016.pdf
March 9, 2016
ISDA responds to FCA consultation paper 15/43 on MIFID implementation
ISDA has responded to the UK Financial Conduct Authority’s (FCA) consultation paper CP 15/43. It is the first FCA consultation on implementation of the revised Markets in Financial Instruments Directive, and at least a further consultation is expected. CP 15/43 seeks views on issues related to the FCA’s regulation of the secondary trading of financial instruments, and some points covered in the consultation may be affected by yet unpublished European Union legislation and guidance.
ISDA - FCA Consultation Paper Response - 8 March 2016 (submitted).pdf
February 2, 2016
JAC response to the ESMA consultation paper on PRIIPs key information documents
On November 10, the European Securities and Markets Authority (ESMA) published a consultation paper on packaged retail and insurance-based investment products (PRIIPs) key information documents (KIDs). The paper sought to establish regulatory technical standards on the presentation and content of the KID, including methodologies for the calculation and presentation of risks, rewards and costs within the document. ISDA has responded to this paper in partnership with ICMA and our members.
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.