EMIR Refit: FCs Reporting on Behalf of Both Itself and NFC- Clients: Operational Considerations

Following the publication of EMIR Refit, as of June 18, 2020, financial counterparties (FCs) will be legally liable for the timely and accurate reporting of over-the-counter (OTC) derivatives contracts on behalf of both themselves and their non-financial counterparty minus (NFC-) clients. This requirement raises several operational challenges and points to be considered by both FC and NFC- entities.

This document captures some of these operational considerations and potential steps FCs and NFCs may need to take (as identified by the ISDA Data and Reporting EMEA Working Group) in order to adhere to this EMIR Refit requirement.

Documents (1) for EMIR Refit: FCs Reporting on Behalf of Both Itself and NFC- Clients: Operational Considerations

CDS Market Dynamics: Record 2025

Global credit default swap (CDS) market activity reached a record $41.8 trillion in 2025, surpassing the previous peak of $38.7 trillion in 2022. Index CDS drove the increase, accounting for 93.3% of total activity and reaching a record $39.0 trillion....

ISDA Letter to BCBS on RMA Models

On July 24, ISDA wrote to the Basel Committee on Banking Supervision (BCBS) to request guidance on how the proposed Risk Mitigation Accounting (RMA) model under International Financial Reporting Standard (IFRS) 9/IFRS 7 should be treated for prudential regulatory capital...