EFAMA appreciates the opportunity to comment on the EMIR 3.0 proposal reforming the clearing framework in the EU. We share the objectives of this review which seek to ensure financial stability in the EU, and the well-functioning of the existing central clearing framework. We understand the objective to reduce excessive exposure to substantially systemic CCPs over time, though we maintain that any regulatory measures should be proportionate to the regulatory rationale, and should not unduly harm market participants.
Annual review 2025-2026
This Review provides a useful overview of the main policy developments we cover, our statistical and research publications, communication outreach, and more, including: a summary of our position on the Market Integration & Supervision Package, the Retail Investment Strategy, the Blueprint for Savings & Investment Accounts, the Supplementary Pensions Package, ELTIF 2.0, the EU securitisation framework, UCITS eligible assets, the implementation of new LMT and LOF rules, sustainability disclosures (CSRD & SFDR), integrated supervisory reporting, tax simplification and neutrality, T+1 settlement, the consolidated tape and EU clearing, tokenisation and AI, and the Financial Literacy Strategy.
