Consultation on the reporting framework under EMIR for clearing activity at recognised third-country CCPs

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Simplification and Burden Reduction
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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 12 October 2026. 

All contributions should be submitted online using the provided reply form in docx format.

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 publicly 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

Personal data contained in the file will be published as submitted. If you don't wish such personal data to be publicly available, you should not include personal data within the document you upload to a public consultation. Alternatively, you may choose the option to not have your response published on the ESMA website. For further details on data processing, please refer to the record register.

Information on data protection can be found in the Legal Notice and Data Protection section.

Who should read this paper?

All interested stakeholders are invited to respond to this consultation paper. In particular, responses are sought from clearing members, counterparties accessing recognised third country central counterparties services as clients of clearing members, as well as recognised TC-CCPs. The paper may also be of interest to industry associations representing market participants, as well as to public authorities and other stakeholders with an interest in clearing markets.

Activity Institution Download
Central Counterparty (CCP) Japan Securities Clearing Corporation 224565
Asset Management E.ON Energy Markets GmbH 225444
Banking DZ BANK AG 225685
Banking French Banking Federation 225710
Others FIA 225715
Others RWE 225751
Government, Regulatory and Enforcement Energy Traders Europe 225831
Banking Association of German Public Banks 225841
Others BDEW e.V. - German Association of Energy and Water Industries (Bundesverband der Energie- und Wasserwirtschaft) 225858
Asset Management DUFAS (the Dutch Fund and Asset Management Association) 225864
Others German Savings Banks Association (DSGV) 225871
Others Stadtwerke München GmbH 225873
Investment Services Swedish Securities Markets Association 225874
Asset Management European Fund and Asset Management Association (EFAMA) 225878
Issuers Deutsches Aktieninstitut e.V. 225879
Investment Services AMF Italia - Associazione Intermediari Mercati Finanziari 225881
Others ISDA 225882
Banking National Association of German Cooperative Banks (BVR) 225885
Central Counterparty (CCP) EACH (European Association of CCP Clearing Houses) 225890
Asset Management Assogestioni 225893
Others Eurelectric 225897
Others Global Legal Entity Identifier Foundation (GLEIF) 225898
Central Counterparty (CCP) CCP Global 225909
Asset Management Association Française de la Gestion Financière (AFG) 225910