On March 26, ISDA and the Association for Financial Markets in Europe submitted a joint response to the European Banking Authority’s (EBA) consultation on implementing technical standards for the 2025 internal models benchmarking exercise. The industry is cognizant of significantly reduced participation in internal models approach benchmarking after implementation of the Fundamental Review of the Trading Book, based on expectations for model applications. The number of firms taking part overall, as well as the number of firms submitting data for specific portfolios, could be lower than the number required to support a meaningful benchmarking exercise. In the response, several issues are identified with the specification of instruments, and it is recommended these specifications are amended to provide greater clarity in the booking of these instruments.