The International Swaps and Derivatives Association (ISDA) has published its response to the Bank of England (BoE)’s consultation on ‘Exempting post‑trade risk reduction transactions from the clearing obligation,’ welcoming the BoE’s proposed principles‑based approach to defining post‑trade risk reduction (PTRR) services and supporting the eligibility criteria for PTRR transactions, including the requirement that they be carried out by a PTRR provider under an eligible agreement and subject to notification conditions. ISDA notes that PTRR services such as portfolio compression, portfolio rebalancing and basis risk optimisation continue to evolve and therefore benefit from a flexible principles‑based framework, while also highlighting that non‑market risk, including counterparty credit risk, may vary within small tolerances across sets of transactions to achieve better overall portfolio outcomes. It suggests that the exemption should become immediately available once the rules are finalised to avoid delay in enabling market participants to reduce risk across their portfolios, and agrees with the Bank’s cost‑benefit assessment that PTRR exercises reduce risk, lower capital and collateral needs, and enhance financial stability by reducing overall collateral demand and mitigating potential ‘dash‑for‑cash’ or ‘dash‑for‑collateral’ dynamics in stressed conditions.

The International Swaps and Derivatives Association (ISDA) has responded to the US Commodity Futures Trading Commission’s (CFTC) proposed amendments to clearing requirements for interest rate swaps to reflect Canadian dollar and Mexican peso (MXN) benchmark transitions. ISDA supported the proposed changes, including the removal of clearing requirements for fixed-to-float swaps referencing the Canadian Dollar Offered Rate and Mexican Interbank Equilibrium Interest Rate, and the expansion of clearing requirements for products referencing the Canadian Overnight Repo Rate Average and MXN Funding TIIE overnight index swaps. ISDA stated that the proposals are consistent with developments in other jurisdictions and agreed with the proposed maturity ranges for the affected products.

The Commodity Futures Trading Commission (CFTC) requested feedback on the use of tokenised collateral and stablecoins in derivatives markets. In its response, the International Swaps and Derivatives Association (ISDA) highlighted that tokenisation could significantly improve collateral mobility, liquidity management, and operational efficiency through near-instantaneous settlement and automation. ISDA noted that these innovations may reduce counterparty and settlement risk, lower transaction costs, and enhance resilience during market stress. It also identified potential applications, such as tokenised money market funds and other eligible assets, which could streamline collateral processes and support 24/7 trading.

The International Swaps and Derivatives Association (ISDA) has responded to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) consultation on updated guidance and public disclosures for central counterparties (CCPs), supporting the proposed measures to improve transparency and the responsiveness of initial margin practices while recommending stronger implementation requirements. ISDA called for CCPs to be required to take the final Basel Committee on Banking Supervision (BCBS)-CPMI-IOSCO recommendations into account, supported by implementation monitoring, and urged retention of stronger requirements for margin simulation tools that replay historical stress events on a day-by-day basis to reflect the path-dependent nature of many margin models. It also recommended greater standardisation of simulator outputs, increased transparency around stress scenarios, and clarified that margin simulators should complement rather than replace disclosures needed to understand and replicate margin models. ISDA further welcomed the proposed quantitative disclosure requirements and backward-looking margin responsiveness measures but argued that the proposed one-year observation period would provide limited value, recommending that CCPs also disclose responsiveness during predefined historical stress periods to better support firms' liquidity planning.

The International Swaps and Derivatives Association (ISDA) has published its response to the European Securities and Markets Authority (ESMA)'s fourth package of Level 2 consultation under the Markets in Financial Instruments Regulation (MiFIR) Review, launched in April 2025. This package focuses on transparency requirements for derivatives, package orders and input/output data for the derivatives consolidated tape. ISDA opposes ESMA's proposal to use modified International Securities Identification Numbers for over-the-counter derivatives, advocating instead for the use of unique product identifiers. It also contests the classification of single name credit default swaps (CDSs) referencing global systemically important banks as liquid instruments, proposing a revised price deferral framework for such contracts. Additionally, ISDA asserts that the proposed price deferral for index CDSs referencing iTraxx indices is insufficient and proposes new price deferral lengths based on implied trade-out time. However, it expresses general support for the deferral framework for interest rate derivatives.

The International Swaps and Derivatives Association (ISDA) submitted a response on 7 April 2025 to the European Securities and Markets Authority (ESMA) consultation on draft regulatory technical standards for central counterparty (CCP) model validation. The consultation, issued under Article 49(5) of the European Market Infrastructure Regulation (EMIR), proposes new quantitative thresholds and qualitative elements for determining significant model changes. ISDA's response requested additional clarification on the proposed thresholds and addressed ESMA's interpretation of concentration risk and lookback periods.

The International Swaps and Derivatives Association (ISDA) has published its response to the European Securities and Markets Authority (ESMA)’s October 2025 consultation on central counterparty (CCP) participation requirements. ISDA broadly supports ESMA’s proposed regulatory technical standards, which aim to ensure fair access and clear membership criteria for CCPs. The response notes that while some requirements may be proportionate to clearing member size, core standards on risk management and operational resilience should remain robust. ISDA also welcomes the inclusion of sponsored models with clearly defined responsibilities and contingency measures, as well as proposals addressing mutualisation risks. However, it emphasises that implementation should be phased to avoid operational disruption, premature position unwinds or market instability, highlighting that abrupt changes could lead to member exits and increased concentration risks.

The International Swaps and Derivatives Association (ISDA) has published its response to the European Securities and Markets Authority (ESMA)’s February 2026 consultation paper on a draft regulatory technical standard (RTS) concerning the post-trade risk reduction (PTRR) exemption from the derivatives clearing obligation under Article 4b of Regulation (EU) 2024/2987 (the European Market Infrastructure Regulation (EMIR)). The response provides drafting suggestions for the proposed RTS and emphasises the importance of maintaining principles-based definitions for eligible PTRR services to allow for ongoing innovation. ISDA notes that existing requirements for risk reduction, market risk neutrality and reporting under Article 9 of EMIR already act as safeguards against circumvention of the clearing obligation, negating the need for specific limitations. It also recommends that reporting and record-keeping requirements for PTRR service providers should avoid duplication and instead leverage exercise performance reports. ISDA further highlights that such providers are already subject to governance, conflict of interest and compliance requirements as investment firms under Directive 2014/65/EU (the Markets in Financial Instruments Directive (MiFID)).

The International Swaps and Derivatives Association (ISDA) has responded to a European Commission Joint Research Centre (JRC) survey on carbon accounting, highlighting broad support among respondents for internationally recognised frameworks, particularly the Greenhouse Gas Protocol and International Organization for Standardization standards. Drawing on input from five ISDA member firms across the banking, exchange and market-data sectors, the response identifies fragmentation across carbon accounting frameworks as the principal challenge, citing duplicated reporting requirements, inconsistent methodologies, differing emissions boundaries and rapidly evolving regulations. Respondents identified Scope 3 emissions, allocation methodologies and a lack of interoperability between frameworks as key obstacles to comparability, efficiency and decision-useful reporting. They called for greater international harmonisation, including common emissions factor databases, interoperable digital reporting standards, automated mapping tools and mutual recognition of assurance processes. Respondents also supported an ‘audit once, report many’ approach to reduce compliance costs and improve consistency for globally active firms.

The International Swaps and Derivatives Association (ISDA) has responded to the Financial Accounting Standards Board (FASB)’s exposure draft on hedge accounting, broadly supporting proposed targeted improvements. These include allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognising all Secured Overnight Financing Rate (SOFR) tenors as benchmark rates and permitting cross-currency swaps with different reset in net investment hedges. ISDA recommends one-time transition relief for HTM securities and an optional modified retrospective approach for existing terms SOFR hedges and calls for finalisation ahead of the 2026 year-end reporting cycle.

The International Swaps and Derivatives Association (ISDA) submitted a response on 30 April 2025 to the Financial Accounting Standards Board's (FASB) proposal on standardising financial key performance indicators for business entities. The response addressed KPI standardisation implications, financial reporting impacts, and cost-benefit considerations for preparers and investors. Based on its analysis, ISDA indicated that KPI standardisation and the proposed disclosures should not be considered urgent FASB priorities.

The International Swaps and Derivatives Association (ISDA) has responded to the Financial Conduct Authority (FCA) consultation paper CP23/28 on updating the regime for money market funds (MMFs). ISDA supports the use of MMFs as collateral for non-cleared derivatives margin requirements and the advancement of tokenised MMFs to be used as collateral to increase collateral mobility, and reduce collateral-related transaction costs and related settlement risks.