On 13 August 2015, the European Securities and Markets Authority (ESMA) published four reports focused on how the European Markets Infrastructure Regulation (EMIR) framework has been functioning and providing input and recommendations to the European Commission’s EMIR Review.
Report no. 1 deals with non-financial counterparties’ (NFC) use of OTC derivatives. We have worked with the European ACT and EU affiliate Treasurer organisations to create this position paper to contest some of the analysis and recommendations made in this report and we urge EU policy makers to reflect on the economic impacts of ESMA’s recommendations. The paper will be presented to ESMA and the European Commission by the EACT during October.
