ESMA publishes a supervisory briefing on the AAR representativeness obligation

CCP 20/02/2026 The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published a supervisory briefing on the representativeness obligation linked to the active account requirement (AAR).

The briefing sets out ESMA’s supervisory expectations for how counterparties should comply with and report on the AAR representativeness obligation. It provides guidance and promotes supervisory convergence for the supervision of counterparties subject to the AAR, an issue which has attracted particular scrutiny.
The document explains how counterparties should identify the most relevant subcategories for the purpose of the AAR representativeness obligation, how they should report trades, and includes an example of compliance with reporting of the representativeness obligation.

ARR representativeness obligation

The representativeness obligation requires relevant counterparties to clear a number of trades in their active accounts open at EU CCPs. These trades must be on the most relevant subcategories of derivatives and reflect the activity those counterparties currently clear at Tier 2 CCPs.

Next steps

Counterparties subject to the AAR representativeness obligation are expected to follow the guidance included in this supervisory briefing to comply with their regulatory obligations.

Further information:

Tayfun Yilmaz

Communications Officer
press@esma.europa.eu

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