Consultation on position calculation under EMIR

Consultation on position calculation under EMIR

from 17 November 2017 to 15 January 2018


Responding to this paper

ESMA invites comments on all matters in this paper and in particular on the specific questions summarised in Annex 1. Comments are most helpful if they:

  1. respond to the question stated;
  2. indicate the specific question to which the comment relates;
  3. contain a clear rationale; and
  4. describe any alternatives ESMA should consider.

ESMA will consider all comments received by 15 January 2018

All contributions should be submitted online at under the heading ‘Your input - Consultations’.

Publication of responses

All contributions received will be published following the close of the consultation, unless you request otherwise.  Please clearly and prominently indicate in your submission any part you do not wish to be publically disclosed. A standard confidentiality statement in an email message will not be treated as a request for non-disclosure. A confidential response may be requested from us in accordance with ESMA’s rules on access to documents. We may consult you if we receive such a request. Any decision we make not to disclose the response is reviewable by ESMA’s Board of Appeal and the European Ombudsman.

Data protection

Information on data protection can be found at under the heading Legal Notice.

Who should read this paper

This consultation paper may be specifically of interest to trade repositories (TRs), trade associations and relevant entities defined in Article 81(3) of Regulation (EU) No 648/2012[1].


[1] Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties and trade repositories OJ L 201 4.7.2012 p. 1-59

Documents available for this Consultation
17/11/2017ESMA70-151-819Consultation paper on position calculation under EMIR
17/11/2017ESMA70-151-819aResponse form EMIR consultation on position calculations


Activity Institution Download
Government, Regulatory and Enforcement Deutsche Bundesbank
Government, Regulatory and Enforcement National Bank of Belgium
Exchanges and Trading Systems London Stock Exchange Group
Others Association of the Luxembourg Fund Industry (ALFI)
Trade Repository KDPW
Trade Repository REGIS-TR S.A.
Trade Repository NEX Abide
Trade Repository CME Group