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ISDA Technical Comments on EC Settlement Finality Regulation

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Summary

On April 9, 2026, ISDA published technical comments on the European Commission's proposed Settlement Finality Regulation addressing designated EU systems and registered third-country systems. ISDA identified concerns about unduly restricted insolvency protections for third-country systems and provided feedback on Financial Collateral Directive changes to facilitate distributed ledger technology implementation.

What changed

ISDA published technical comments responding to the European Commission's proposed Settlement Finality Regulation, which would establish rules for designated EU systems and registered third-country systems. The comments highlight that the scope of insolvency protections for registered third-country systems is unduly restricted under the proposed framework. ISDA also addressed proposed changes to the Financial Collateral Directive aimed at facilitating distributed ledger technology implementation in collateral arrangements.

Financial institutions engaged in cross-border settlement, derivatives counterparties, and firms exploring DLT-based collateral solutions should monitor this regulatory development. The EC's proposal, once finalized, could significantly affect how third-country clearing and settlement systems access EU insolvency protections and how financial institutions implement emerging technologies for collateral management.

What to do next

  1. Monitor for EC Settlement Finality Regulation developments
  2. Review comments on third-country system insolvency protections
  3. Assess DLT implications for collateral arrangements

Archived snapshot

Apr 10, 2026

GovPing 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.

  1. Public Policy
  2. Europe
  3. ISDA Response to EC’s Settlement Finality Regulation Proposal

ISDA Response to EC’s Settlement Finality Regulation Proposal

On April 9, ISDA published technical comments on the European Commission’s (EC) proposed Settlement Finality Regulation (SFR) as it applies to designated EU systems and registered third-country systems. One significant concern is that the scope of insolvency protections provided to registered third-country systems by the new framework is unduly restricted. The technical comments also cover proposed changes to the Financial Collateral Directive to facilitate the implementation of distributed ledger technology.

Tags:

Digital, Distributed Ledger Technology (DLT), European Commission (EC), Legal

Documents (1)

Latest

Response on EC’s SFR Proposal

On April 9, ISDA published technical comments on the European Commission’s (EC) proposed Settlement Finality Regulation (SFR) as it applies to designated EU systems and registered third-country systems. One significant concern is that the scope of insolvency protections provided to...

Natixis CIB Adopts ISDA’s DRR

ISDA has announced that Natixis CIB has adopted ISDA’s Digital Regulatory Reporting (DRR) solution, enabling the bank to meet regulatory reporting requirements more efficiently and accurately. The ISDA DRR uses the Common Domain Model (CDM) – an open-source data standard...

Paper on MIFIR PTT

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...

Data Integrity for Single-sided Reporting

On April 2, ISDA published a paper on why single-sided reporting does not compromise the quality and integrity of data received by supervisors. The paper addresses concerns among regulators that moving from dual-sided reporting would adversely affect the quality of...

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Last updated

Classification

Agency
ISDA
Instrument
Notice
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Financial advisers Insurers Investors
Industry sector
5231 Securities & Investments
Activity scope
Derivatives settlement Collateral transfers Regulatory reporting
Geographic scope
European Union EU

Taxonomy

Primary area
Securities
Operational domain
Legal
Topics
Financial Services Payments

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