The International Swaps and Derivatives Association (ISDA) has published a paper on assessing the EU clearing landscape following the implementation of the European Market Infrastructure Regulation 3.0 (EMIR 3.0). ISDA stated that the Active Account Requirement (AAR) has strengthened the operational resilience of EU counterparties by requiring certain firms to maintain clearing accounts at EU central counterparties (CCPs), providing fallback arrangements in the event of operational disruption or stress at third-country CCPs. The paper noted that clearing activity at EU CCPs, including Eurex, has increased since the introduction of the AAR, although ISDA said it remains too early to assess the full impact of the regime. ISDA argued that existing supervisory powers under EMIR 2.2 already address financial stability risks linked to UK CCPs and called on the European Commission to grant stable, non-time-limited equivalence for UK CCPs to preserve EU firms’ access to global liquidity pools. The paper also proposed additional measures to improve the competitiveness and attractiveness of EU CCPs, including promoting voluntary clearing by public entities, enabling cross-margining, facilitating centrally cleared repo transactions, supporting the use of tokenised collateral and strengthening the EU porting framework.