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Trade associations urge EC to delay EMIR 3.0 reporting for third-country CCPs

22 October 2025

FIA and nine other Trade Associations  – the Alternative Investment Management Association, the European Association of Co-operative Banks, the European Association of Corporate Treasurers, the European Banking Federation, the European Fund and Asset Management Association, the European Principal Traders Association, the European Venues and Intermediaries Association, the International Swaps and Derivatives Association and the Managed Funds Association –  wrote to the European Commission requesting a delay to reporting obligations and seeking guidance that counterparties are not required to report information on clearing activity on third-country central counterparties (CCPs) under Article 7d of the European Market Infrastructure Regulation (EMIR 3.0) until the corresponding regulatory technical standards and implementing technical standards are applicable.

The Associations highlight that implementing reporting prematurely, even on an interim basis, would place an undue operational burden on European firms, create legal uncertainty and offer limited value for supervision.

Read full letter here.

  • FIA
  • Compliance
  • Recordkeeping and reporting
  • Advocacy
  • Europe