The International Swaps and Derivatives Association (ISDA), Futures Industry Association (FIA), Global Financial Markets Association (GFMA), Commodity Markets Council (CMC) and China Mite Capital Exchange (CMCE) (the Associations) have responded to the International Organization of Securities Commission (IOSCO)’s consultation report on good practices for over-the-counter (OTC) commodity derivatives markets, supporting objectives of safeguarding market integrity, orderly trading conditions and resilience, while opposing new or duplicative reporting requirements. The Associations emphasise more effective use of existing OTC derivatives data, enhanced cross-border data sharing and strengthened cooperation between authorities, warning that additional reporting obligations, including mandatory OTC position reporting, could create significant burden, duplication and barriers to entry. They also highlight concerns around regulatory overreach, data confidentiality, economically equivalent OTC (EEOTC) definition changes and expansion of the financial regulatory perimeter to physically settled commodity forwards, advocating a proportionate, risk-based approach based on existing frameworks.