On May 17, ISDA published its comments on the European Commission’s active account proposal under the European Market Infrastructure Regulation (EMIR) requiring EU clearing participants to use EU central counterparties (CCPs) for a proportion of their business. ISDA explains that such a proposal would not make the EU derivatives market safer or more attractive, and could lead to market fragmentation, potentially creating systemic and operational risks. The comments also set out why mandating clearing on EU CCPs is unlikely to generate a viable and attractive euro clearing market.