Updating and improving EMIR – Europex comments on Commission’s EMIR amendment proposal

Brussels, 13 October 2017 | Europex welcomes the European Commission’s recently tabled EMIR amendment proposal that is currently being discussed by the European Parliament and the Council. We strongly support its aim to simplify reporting obligations and improve data quality. We believe that the proposal takes the right approach by reducing the burden on Non- Financial Counterparties (NFCs) and smaller Financial Counterparties (FCs). We explicitly share the goal to increase transparency with respect to clearing and reporting.

In the following, we would like to comment on four key aspects of the Commission’s proposal:

1. Single-sided reporting by Central Counter Parties (CCPs) for exchange-traded derivatives (ETDs) is the right way forward;

2. Simplified reporting and clearing obligations will help to reduce complexity for both FCs and NFCs;

3. The measures to increase the transparency and predictability of CCPs’ initial margin requirements will be beneficial to market stakeholders;

4. The entry into force of the new reporting standards should be done over a weekend to minimise disruption to customers and allow system operators maximum time to test new code and other updates.

Please find our detailed remarks below.