The International Swaps and Derivatives Association (ISDA), Commodity Markets Council Europe, Energy Traders Europe and FIA have submitted a joint response on to the Financial Conduct Authority's (FCA)'s consultation CP26/8, supporting an increase in the commodity derivatives clearing threshold under UK European Market Infrastructure Regulation from €3bn to €6bn rather than the proposed €5bn. They argued that the threshold, which has not been reviewed for over a decade, has materially diminished in real terms due to inflation, sustained increases in commodity prices, expanded market participation and heightened volatility, and no longer reflects current market conditions or risks. The response explained that firms typically manage activity well below the formal threshold to avoid the costs and liquidity pressures associated with mandatory clearing and margining, meaning the effective threshold is significantly lower in practice and may create procyclical effects during periods of market stress. The organisations emphasised the distinct characteristics of commodity derivatives markets, which are closely linked to physical production and commercial risk management, and warned that an inadequately calibrated threshold risks constraining hedging activity, reducing liquidity and undermining UK competitiveness. They concluded that a higher interim threshold is necessary to support proportionate regulation and market functioning while HM Treasury undertakes its broader review of the UK EMIR clearing framework, and that the threshold should not be reduced below €6bn.