On September 23, ISDA, the Alternative Investment Management Association (AIMA), the European Banking Federation (EBF), the European Fund and Asset Management Association (EFAMA) and FIA sent a letter urging the European Commission and European supervisory authorities to clarify that market participants are not required to implement the European Market Infrastructure Regulation (EMIR 3.0) Level 1 provisions prior to the date of application of the associated Level 2 regulatory technical standards (RTS).

In the letter, the associations state this is to avoid firms being required to implement the requirements of EMIR 3.0 twice—first, to comply with the Level 1 provisions once EMIR 3.0 enters into force and then when the associated Level 2 RTS becomes applicable.