Consultation on post trade risk reduction services with regards to the clearing obligation (EMIR Article 85(3a))

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Type of event
Post Trading
Supervisory convergence

Responding to this paper

ESMA invites responses to the questions set out throughout its Consultation Paper on the Report on post trade risk reduction services with regards to the clearing obligation that ESMA is drafting under Article 85(3a) of the Regulation (EU) No 648/2012 of the European Parliament and Council on OTC derivatives, central counterparties and trade repositories (EMIR, as amended by Refit).


Responses are most helpful if they:


·                respond to the question stated;

·                contain a clear rationale; and

·                describe any alternatives ESMA should consider.

ESMA will consider all responses received by 15 June 2020.


In order to facilitate analysis of responses to the Consultation Paper, respondents are requested to follow the below steps when preparing and submitting their response:

·                Insert your responses to the questions in the Consultation Paper in the present response form.

·                Please do not remove tags of the type <ESMA_QUESTION_PTRR_1>. Your response to each question has to be framed by the two tags corresponding to the question.

·                If you do not wish to respond to a given question, please do not delete it but simply leave the text “TYPE YOUR TEXT HERE” between the tags.

·      When you have drafted your response, name your response form according to the following convention: ESMA_PTRR_nameofrespondent_RESPONSEFORM. For example, for a respondent named ABCD, the response form would be entitled ESMA_PTRR_ABCD_RESPONSEFORM.

·         Upload the form containing your responses, in Word format, to ESMA’s website ( under the heading “Your input – Open consultations” à “Consultation Paper on post trade risk reduction services with regards to the clearing obligation (EMIR Article 85(3a))”.

Publication of responses

All contributions received will be published following the close of the consultation, unless you request otherwise. Please clearly indicate by ticking the appropriate checkbox on the website submission page if you do not wish your contribution to be publicly disclosed. 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 “Data protection”.

Who should read the Consultation Paper

All interested stakeholders are invited to respond to this consultation paper. In particular, responses are sought from financial and non-financial counterparties of OTC derivative transactions as well as central counterparties (CCPs) and clearing members.

Activity Institution Download
Others ISDA
  • 55939
Banking French Banking Federation
  • 55795
Others Swedish Securities Dealers Association
  • 55817
Banking Kommunalbanken AS
  • 55830
Central Counterparty (CCP) Eurex Clearing (ECAG)
  • 55881
Central Counterparty (CCP) European Association of CCP Clearing Houses
  • 55894
Central Counterparty (CCP) LSEG
  • 55895
Others IHS Markit
  • 55906
Others European Federation of Energy Traders (EFET)
  • 55908
Asset Management European Fund and Asset Management Association (EFAMA)
  • 55951
Others CME Group Inc.
  • 55936
Asset Management Citadel
  • 55937
Others ESRB
  • 55988