On November 12, ISDA, along with 13 other trade associations, wrote to the European Commission to ask them to  extend the temporary equivalence until the date 18 months after entry into force of the relevant Commission delegated acts under EMIR 2.2, plus an additional three month period to allow UK CCPs to serve termination notices to EU clearing members in the event that their recognition is withdrawn following ESMA’s review.

It is important for the purpose of maintaining financial stability in the event of a “No Deal” Brexit for the Commission to provide this certainty in a timely fashion. We respectfully but urgently request the Commission to provide this confirmation well in advance of the end of December 2019 in order to mitigate the effects on EU counterparties and clearing members in the event that UK CCPs cannot obtain permanent recognition prior to March 30, 2020.