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Response to ESMA consultation on EMIR 3 draft RTS on Margin Transparency requirements

15 September 2025
  • We fully endorse the improved transparency provisions of Article 38 of EMIR, and overall agree with ESMA’s interpretation thereof
  • The greater transparency helps clients better understand and manage their margin requirements – particularly during periods of market stress
  • The conditions between the validity and the nonvalidity of the margin-model assumptions (e.g., in stress scenarios) should clearly be delineated by CCPs, along with the implications on margin requirements of the nonvalidity of the assumptions (e.g., manual override)
  • Transparency should also be ensured on the conditions which may trigger unscheduled intraday margin calls
  • In general, CSPs should transmit to their clients all information on margin requirements provided by CCPs as-is
  • CSPs should provide their clients with information on any additional requirements they may apply, distinguishing it from those of the CCP
  • When CSPs share margin data with their clients (e.g., through the simulation tool) they shall respect confidentiality of client information, ensuring that data is disaggregated by client and that each client only receives data regarding its own portfolios

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