More changes are underway for EU market participants subject to the clearing obligation. The European Commission’s EMIR 3.0 legislative proposal from December 2022 foresees the obligation to maintain an active account with an EU CCP for systemically relevant products, i.e., IRS in Euro and Zloty, CDS in Euro, and STIR in Euro for a (yet to be defined) proportion of their business. With Eurex Clearing, you can already set up this account, be ahead of the curve, and reap the benefits of an EU-based CCP account.
Swaps activity award
To support buy-side clients to clear OTC interest rate derivatives positions in the EU, Eurex Clearing prolongs its OTC IRD Client Activation Program. Registration for the incentive program is possible until 31 December 2023.
Expected next steps
While EMIR 3.0 is still subject to the usual legislative procedure, the proposal suggests that the transition takes place in two steps:
Step 1 – onboarding and readiness by early 2024*
Onboarding and readiness: in-scope market participants must set up an account and ensure readiness when the final legislation (Level 1) becomes effective.
Step 2 – activation by early 2025*
Activation: in-scope market participants must meet the, to be defined, activity target levels in line with Level 2 standards.
* indicative timeline which may be subject to change depending on the legislative process
Did you know…?
The European Commission’s impact assessment finds that 40% of the in-scope firms have not onboarded yet. Check your status and which capacities to consider to meet the requirement.
The onboarding timeline for your active account under EMIR 3.0 depends on various internal and external factors. Eurex Clearing, therefore, encourages market participants to act swiftly ahead of the proposed timelines to avoid onboarding capacity constraints closer to the deadlines.
Onboarding and readiness: capacity considerations
The client and the clearing broker will both need to assign legal resources to negotiate and review the clearing agreement.
Accounts will be required with the clearing broker and on behalf of the client at Eurex Clearing. If the client demands CCP reporting, additional lead time will be needed.
The middleware static data setup and technology layer implementation will be needed as well.
Activation: capacity considerations
Setting up and testing the trade execution and clearing workflow (which may require the brokers’ and the clearing brokers' support) will be required. In addition, considerations need to include a full front-to-back review of the cleared workflow.
Trading workflow setup
Client cleared workflow setup
Considerations should include optimizing collateral and margin requirements to maintain an active account with an EU CCP.
Client workflow setup - multi-CCP/multi-clearing broker