EFAMA has submitted its response to ESMA’s consultation on the Active Account Requirements (AAR).   Our industry stands ready to implement the AAR by June 2025... However, we have strong reservations about the heavy and redundant reporting requirements.  Our streamlined proposal aligns deadlines and reduces the actual number of reports, supporting the European Commission’s push for simplification.  We also call for an exemption that can scope in more clearing counterparties from Day 1, with the result that these entities will clear exclusively or almost exclusively on an EU CCP.