ISDA Responds to ESMA on PTRR Clearing Exemption
Summary
ISDA submitted a response on April 20, 2026 to ESMA's consultation paper on a draft regulatory technical standard (RTS) for the post-trade risk reduction (PTRR) exemption from the derivatives clearing obligation under Article 4b of EMIR. ISDA recommends maintaining principles-based definitions for eligible PTRR services to allow ongoing innovation, argues existing EMIR Article 9 reporting requirements serve as de facto safeguards against clearing obligation circumvention, and suggests that reporting and record-keeping requirements for PTRR service providers should avoid duplication with existing investment firm obligations under MiFID.
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GovPing monitors ISDA News for new banking & finance regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 24 changes logged to date.
What changed
ISDA submitted comments to ESMA's draft regulatory technical standard establishing the conditions for the PTRR exemption from the EMIR derivatives clearing obligation. The response addresses four areas: eligible PTRR service definitions, safeguards against clearing obligation circumvention, provider reporting and record-keeping requirements, and governance and conflicts of interest obligations.
Financial institutions that operate or use PTRR services should monitor ESMA's final RTS and ensure their arrangements align with the emerging standards, particularly regarding risk reduction requirements and existing EMIR Article 9 reporting obligations that ISDA identifies as de facto safeguards.
Archived snapshot
Apr 23, 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.
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- ISDA Responds to ESMA on PTRR Clearing Exemption
ISDA Responds to ESMA on PTRR Clearing Exemption
On April 20, ISDA submitted a response to the European Securities and Markets Authority (ESMA) consultation paper on a draft regulatory technical standard (RTS) for the post-trade risk reduction (PTRR) exemption from the derivatives clearing obligation under Article 4b of the European Market Infrastructure Regulation (EMIR).
In the response, ISDA provides drafting suggestions for the proposed RTS and makes the following comments:
- On the description of eligible PTRR services, ISDA emphasizes the importance of keeping principles-based definitions to allow for ongoing innovation;
- On safeguards to avoid circumvention of the clearing obligation, ISDA notes that existing requirements to benefit from the exemption, in terms of risk reduction, market risk neutrality and existing reporting under Article 9 of EMIR already act as de facto safeguards, so there is no need for any specific limitations to be added;
- On requirements for PTRR service providers, ISDA suggests that reporting and record-keeping requirements should avoid duplication and leverage the exercise performance report;
- On governance, conflicts of interest and compliance requirements, PTRR service providers are already subject to requirements on these matters as investment firms under the Markets in Financial Instruments Directive. Tags:
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