The International Swaps and Derivatives Association suggests streamlining margin information sharing directly between CCPs and clients to improve clarity and operational efficiency under EU’s new regulatory standards.

The International Swaps and Derivatives Association (ISDA) recently submitted its feedback regarding the European Securities and Markets Authority’s (ESMA) consultation on draft regulatory technical standards (RTS) that focus on margin transparency rules under the European Market Infrastructure Regulation (EMIR 3.0). ISDA voiced support for the general idea that margin transparency is important but also called for a more streamlined way to put it into practice. From their perspective, the current ESMA plan—which involves central counterparties (CCPs) providing model transparency and simulation tools to clearing service providers who then pass that info to clearing members and clients—is more complicated than it needs to be. Instead, ISDA recommends that CCPs should directly share their model documentation and simulators with clients, making the process clearer and cutting out some unnecessary steps.

This recommendation is based on a small study conducted by seven of ISDA’s members who offer clearing services in the EU. The study showed that only about 7% of their clients pay margin multipliers or other kinds of extra margin above the CCP’s standard requirements. So, basically, most clients could probably get enough information by just accessing the CCP’s simulators directly. When additional, client-specific multipliers do apply, the providers could offer extra details if asked, or show historical examples of how those multipliers have been used in real cases. Another idea is that they could share hypothetical scenarios to help clients understand how margin multipliers work—this might make things clearer without creating unnecessary clutter.

This response is part of ESMA’s bigger effort, which started back in June 2025, to hear out different stakeholders about transparency and cost disclosures related to clearing services, especially with regards to CCP margin simulation tools. The goal of these consultations under EMIR 3.0 is to come up with final standards that will improve how clear and accessible margin information is for market participants. The final report is scheduled to be sent to the European Commission by December 2025.

ISDA’s stance here isn’t new. It has generally promoted transparency and good governance in clearing markets. For example, in 2024, ISDA and the Institute of International Finance jointly pushed for better transparency about initial margin (IM) requirements through more detailed CCP disclosures. They've always emphasized balancing transparency with operational efficiency—something that’s come up repeatedly. You can see this in their 2022 response to ESMA on anti-procyclicality tools and margin governance issues.

The importance of transparency around margins isn’t just theoretical either. ISDA’s latest annual survey found that, by the end of 2024, the biggest derivatives firms were holding around $1.5 trillion in margin for non-cleared derivatives—up 6.4% compared to the previous year. Plus, they reported posting nearly $390 billion of initial margin to CCPs for interest rate derivatives and credit default swaps. This huge amount of margin underscores how vital it is to have clear, accessible info to support market confidence and help manage operational risks effectively.

Although ESMA’s consultation aims to boost transparency and disclosing costs across the clearing ecosystem, ISDA’s response leans more toward practical concerns—namely, that the current setup might be a bit over-complicated and could be made more efficient. They’re suggesting that direct access to CCP margin models could help cut down on communication layers and make markets work more smoothly overall. It’s a nuanced view, for sure, reflecting ongoing industry efforts to ensure that regulations promote both transparency and operational practicality within the EU and beyond.


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Source: Noah Wire Services

Verification / Sources

  • https://www.isda.org/2025/09/10/isda-response-to-esma-on-margin-transparency/ - Please view link - unable to able to access data
  • https://www.esma.europa.eu/press-news/esma-news/esma-consults-margin-transparency-and-cost-clearing - On 24 June 2025, the European Securities and Markets Authority (ESMA) launched two public consultations following the review of the European Market Infrastructure Regulation (EMIR 3). The consultations seek stakeholders' views on the type of information to be disclosed by clearing service providers to their clients regarding costs and fees for clearing services, and on the requirements for central counterparties' (CCPs) margin simulation tools and clearing service providers' margin simulations. The deadline for responses was 8 September 2025, with final reports to be submitted to the European Commission by 25 December 2025.
  • https://www.esma.europa.eu/press-news/consultations/consultation-emir-3-draft-rts-margin-transparency-requirements - ESMA invited comments on all matters in the Consultation Paper on EMIR 3 draft Regulatory Technical Standards (RTS) on Margin Transparency requirements, particularly on specific questions summarised in Annex 1. The consultation aimed to gather feedback from stakeholders to inform the development of the final draft RTS, which was to be submitted to the European Commission by 25 December 2025.
  • https://www.isda.org/2022/04/04/isda-responds-to-esma-on-margin-procyclicality-tools/ - In April 2022, ISDA responded to ESMA's consultation on margin procyclicality tools. ISDA members welcomed the consultation and ESMA's analytical work on anti-procyclicality (APC) tools. They encouraged ESMA to move forward on transparency, disclosure, and governance components to make APC tools effective, proposing that the whole clearing market and regulators agree to a target level of procyclicality that balances the cost of clearing with stability.
  • https://www.isda.org/2024/04/16/isda-response-to-margin-transparency-consultation/ - In April 2024, ISDA and the Institute of International Finance (IIF) responded to the Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI), and International Organization of Securities Commissions (IOSCO) consultation on transparency and responsiveness of initial margin in centrally cleared markets. The associations supported enhancing transparency on cleared margin for all market participants, noting it should start with central counterparties (CCPs) making fundamental disclosures about their margin models.
  • https://www.isda.org/2025/05/14/isda-margin-survey-shows-leading-derivatives-firms-collected-1-5-trillion-of-margin-at-year-end-2024/ - ISDA published its latest annual margin survey, showing that initial margin (IM) and variation margin (VM) collected by leading derivatives market participants for their non-cleared derivatives exposures increased by 6.4% to $1.5 trillion at the end of 2024. The survey also reported that $389.8 billion of required IM was posted by all market participants to central counterparties for their cleared interest rate derivatives and single-name and index credit default swap transactions at the end of 2024.
  • https://www.isda.org/2025/07/08/isda-response-to-esma-mifir-review-consultation/ - On 11 July 2025, ISDA submitted a response to ESMA's fourth package of Level 2 consultation under the Markets in Financial Instruments Regulation Review (MIFIR), focusing on transparency for derivatives, package orders, and input/output data for the derivatives consolidated tape. ISDA argued against ESMA's proposal to use a modified ISIN as the identifier for over-the-counter (OTC) derivatives in scope for transparency, advocating for the unique product identifier as the correct identifier for OTC derivatives.

Noah Fact Check Pro

The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.

Freshness check

Score: 10

Notes: The narrative is current, dated 10 September 2025, and pertains to recent developments in margin transparency under EMIR 3.0. The European Securities and Markets Authority (ESMA) launched consultations on this topic on 24 June 2025, with a deadline for responses on 8 September 2025. (esma.europa.eu) The ISDA's response aligns with this timeline, indicating freshness.

Quotes check

Score: 10

Notes: The narrative does not contain direct quotes, suggesting originality.

Source reliability

Score: 10

Notes: The narrative originates from the International Swaps and Derivatives Association (ISDA), a reputable organisation in the financial industry.

Plausability check

Score: 10

Notes: The claims made in the narrative are plausible and consistent with known industry practices and recent regulatory developments.

Overall assessment

Veredict (FAIL, OPEN, PASS): PASS

Confidence (LOW, MEDIUM, HIGH): HIGH

Summary: The narrative is current, original, and originates from a reputable source. The claims are plausible and consistent with recent regulatory developments, indicating a high level of credibility.