The European Association of CCP Clearing Houses (EACH) has submitted its response to the European Securities and Markets Authority (ESMA) consultation on EMIR 3 draft Regulatory Technical Standards (RTS) on Margin Transparency.
EACH welcomes ESMA’s aim to enhance transparency and support market participants in strengthening liquidity risk management. However, EACH stresses that new requirements must not undermine the competitiveness of EU CCPs or create disproportionate operational burdens, given that CCPs already provide extensive information through existing tools, documentation, and public disclosures.
EACH calls for:
- Avoiding duplication of requirements already covered under existing regulations;
- Safeguarding intellectual property to protect CCPs’ competitive position;
- Focusing on usability rather than overly prescriptive technical detail;
- A proportionate, phased implementation, with final RTS rules entering into force no earlier than 18 months after publication to allow operational readiness.
EACH also highlights that overly detailed requirements for simulation tools, stress scenarios, or model assumptions could raise costs without clear benefits for clearing members. A more balanced, outcome-focused approach would ensure transparency while preserving EU CCPs’ competitiveness and market stability.
The full EACH response is available here.
