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ESMA consults on reporting framework for clearing activity at recognised third-country CCPs

AI Analysis

ESMA launched a consultation on draft Regulatory Technical Standards and Implementing Technical Standards for the annual EMIR Article 7d reporting of clearing activity conducted through recognised third-country CCPs. The proposal would give EU competent authorities and ESMA a harmonised view of firms’ exposures, including cleared volumes, margins, default-fund contributions and largest payment obligations, while reusing data already available through existing reporting channels.

Key dates

2026-08-18
ESMA launched the consultation on draft EMIR RTS and ITS for annual reporting of clearing activity at recognised third-country CCPs.
2026-10-12 Deadline
Deadline for stakeholders to provide feedback on the reporting framework, templates and format.

Suggested considerations

  • Compliance teams may wish to submit comments on the proposed framework, templates and reporting format by 2026-10-12.
  • Firms should consider identifying every recognised third-country CCP used by their EU entities and distinguishing direct clearing-member activity from client clearing activity.
  • Reporting owners may wish to map the proposed Article 7d data points to existing EMIR Article 9 transaction reporting, margin, collateral, default-fund and treasury or payments data to determine what can be reused and what new data controls are needed.
  • Groups should consider determining whether reporting will be performed by each EU entity or by the EU parent undertaking on a consolidated basis.
  • Firms may wish to assess data availability by asset class and Union currency, calculation methodologies for annual average cleared values, and controls for margins, default-fund contributions and largest payment obligations.
  • Technology and regulatory-reporting teams should consider designing provisional data lineage, reconciliation and governance processes, while treating implementation dates and final fields as subject to the final RTS and ITS.
  • Firms should monitor ESMA’s Final Report and the subsequent adoption, endorsement and publication of the technical standards before treating the proposed reporting model as a final operative obligation.

What changed

This is a consultation rather than a final binding rule. ESMA proposes the reporting framework, templates and format required under EMIR 3 Article 7d for clearing members and clients that clear transactions through recognised third-country CCPs. Firms established in the EU and not part of an EU-consolidated-supervision group would report to their competent authority; where the firm belongs to such a group, the EU parent undertaking would report on a consolidated basis. The annual report is expected to cover the types of financial or non-financial instruments cleared, average annual values cleared by Union currency and asset class, margins collected, default-fund contributions and the largest payment obligation. ESMA states that requirements would be limited to information not already avail

Compliance impact

The proposal would create a new harmonised annual reporting obligation under EMIR 3 Article 7d for relevant EU clearing members and clients, with possible consolidated reporting by EU parent undertakings. The immediate impact is preparatory because the consultation does not itself impose a final submission deadline; however, the data scope identified in related market commentary indicates potentia

Who is affected

  • EU-authorised clearing members of recognised third-country CCPs
  • EU clients that clear transactions through recognised third-country CCPs
  • EU parent undertakings of groups subject to consolidated supervision where group entities conduct the relevant clearing activity
  • EU competent authorities and ESMA
  • European Market Infrastructure Regulation (EMIR)
  • EMIR 3
  • EMIR Article 7d
  • EMIR Article 9

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

What the ESMA said

ESMA consults on reporting framework for clearing activity at recognised third-country CCPs 18 August 2026 CCP Simplification and Burden Reduction The European Securities and Markets Authority (ESMA), the EU's financial markets regulator and supervisor, has launched a consultation on a proposed annual reporting…

Extract from ESMA . Read the full notice at the source for the authoritative text.

Relevant Firm Types

BankBroker DealerHedge FundAsset Manager
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