Joint Energy Association Group’s call for swift adoption of EMIR 3 revised clearing threshold calculation methodology

Joint statement Download PDF

On behalf of the Joint Energy Associations Group (JEAG) composed of BDEW, EFET, Eurelectric, Eurogas
and IOGP, we are supportive of the changes proposed by all three EU co-legislators with regard to the
EMIR 3 proposal. These are an appropriate response to the challenges faced by energy market
participants during the energy crisis in 2022 to guarantee a secure, affordable and sustainable energy
supply and will contribute to fostering transparent and safe European financial markets. 
Key points:
• We are fully supportive of the proposals of all three EU co-legislators to install a new
calculation methodology for the clearing threshold for non-financial counterparties (NFCs).
We urge its immediate application without any delay as this is essential to develop
competitive and liquid energy markets and support the energy transition.
• We are fully supportive of the further changes proposed by all three EU co-legislators with
relevance for NFCs, in particular to guarantee the transparency of margin calls, the use of
uncollateralised bank guarantees as eligible collateral and the direct access of NFCS to
central clearing.
• We welcome the retention of the exemption for NFCs from intra-group reporting as
proposed by the European Parliament and the Council.


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