FIA, AIMA, EBF, EFAMA and ISDA have sent a letter urging the European Commission and European Supervisory Authorities to clarify that market participants are not required to implement the European Market Infrastructure Regulation (EMIR 3.0) Level 1 provisions prior to the date of application of the associated Level 2 regulatory technical standards (RTS).
In the letter, the associations state this is to avoid firms being required to implement the requirements of EMIR 3.0 twice – first, to comply with the Level 1 provisions once EMIR 3.0 enters into force and then when the associated Level 2 RTS becomes applicable.
This would impose disproportionate and unnecessary costs and would not provide any substantial benefits, the associations say.
Read the letter in full.