It has been 10 years since policy-makers came together through the Group of 20 (G-20) to agree a globally consistent regulatory agenda for derivatives. Since then, substantial progress has been made at the national level to implement rules on clearing, margin, trading, capital in line with the G-20 standards. Derivatives markets are safer, more transparent and more resilient as a result.

But while this progress is unmistakable, these regulatory reform efforts often differ in substance, scope and timing across jurisdictions. This has led to inefficiencies and higher costs for derivatives users, and ultimately results in increased risk.

This paper identifies examples of differences in how global standards have been implemented in individual jurisdictions, and recommends a series of steps that can be taken to address this issue. In particular, ISDA believes that global standard-setting bodies have a role to play in ensuring greater consistency in how rules are implemented, and in achieving a predictable, consistent and timely substituted compliance framework.