Joint Paper on MIFIR PTT Proposals in EC Market Integration Package
Summary
ISDA, AFME, ICMA and EBF published a joint paper supporting the European Commission's proposals under MIFIR to narrow post-trade transparency (PTT) requirements. The associations back removing forward rate agreements and basis swaps from public transparency due to their illiquid nature, and support disapplying PTT for OTC derivatives on certain third-country trading venues. The paper urges co-legislators to extend these exemptions to all asset classes and to transactions executed away from trading venues.
What changed
Four major financial industry associations published a position paper responding to the European Commission's Market Integration and Supervisions Package proposals on MIFIR post-trade transparency. The paper endorses the EC's specific proposals to remove forward rate agreements and basis swaps from public transparency requirements and to disapply PTT for OTC derivatives on qualifying third-country trading venues. The associations argue these measures recognize the illiquid nature of certain instruments and align with existing ESMA guidance.
For affected market participants including broker-dealers and asset managers trading OTC derivatives, the paper signals industry support for narrowing PTT obligations. If co-legislators adopt these proposals, entities trading forward rate agreements, basis swaps, or using third-country trading venues may face reduced transparency reporting burdens. The paper's call for broader exemption scope suggests ongoing advocacy for further PTT relief across all asset classes and off-venue transactions.
What to do next
- Monitor EC legislative developments on MIFIR PTT reforms
- Review current post-trade transparency compliance obligations
- Assess potential impact of proposed exemptions on derivatives reporting
Archived snapshot
Apr 8, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
- Public Policy
- Europe
- ISDA, AFME, ICMA and EBF Publish Paper on Proposals Relating to MIFIR PTT in the EC’s Market Integration and Supervision Package
ISDA, AFME, ICMA and EBF Publish Paper on Proposals Relating to MIFIR PTT in the EC’s Market Integration and Supervision Package
On April 7, ISDA, the Association for Financial Markets in Europe (AFME), the International Capital Market Association (ICMA) and the European Banking Federation (EBF) published a paper on proposals relating to post-trade transparency (PTT) under the Markets in Financial Instruments Regulation (MIFIR) contained in the European Commission’s (EC) Market Integration and Supervisions Package.
The paper supports the EC’s proposal to remove forward rate agreements and basis swaps from the scope of public transparency due to their illiquid nature and provides supporting arguments for the proposal. The paper also supports the existing proposal to disapply PTT requirements under MIFIR for over-the-counter derivatives concluded on certain third-country trading venues, effectively superseding an existing European Securities and Markets Authority opinion that currently provides for this. However, the paper urges the EC and co-legislators to be more ambitious by extending the scope of the proposal to cover all asset classes in the scope of PTT and to disapply PTT for transactions executed away from trading venues and made public on suitably qualified third-country approved publication arrangements.
Tags:
ESMA, Europe, European Commission (EC), MIFIR, Transparency
Documents (1)
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