Joint Response to ECB Consultation on Options and Discretions under EU Law

On January 24, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Central Bank’s (ECB) consultation on its approach to options and discretions under EU law. In the response, the associations highlight the efforts of the ECB to establish consistent options and discretions that would harmonize rules and foster a level playing field in the euro area. The response also mentions that further actions are necessary, specifically on trading book boundary classifications and exemptions.

The response includes a comprehensive set of recommendations that the associations urge the ECB to consider, as these suggestions will provide crucial certainty to banks in their implementation of the third Capital Requirements Regulation.

Documents (1) for Joint Response to ECB Consultation on Options and Discretions under EU Law

Calibration Test – IQ September 2026

Calibrating capital requirements is a highly complex undertaking and getting it wrong can have serious consequences. Too much lenience might lead to banks holding insufficient capital to mitigate their risks. But excess conservatism can put balance sheets under strain, forcing...

Remove Bureaucracy from Cross-margin Approvals

Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...