ESMA

European Securities and Markets Authority

Medium Impact

ESMA consults on annual reporting framework for EU clearing activity at recognised third-country CCPs

Published

Aug 18, 2026

Topics

EMIR, Third-country CCPs, Clearing, Regulatory reporting, RTS/ITS, Supervisory data

Executive Summary

ESMA has opened a consultation on a proposed annual reporting framework under EMIR for clearing activity conducted by EU clearing members and clients at recognised third-country central counterparties. The proposal comprises draft Regulatory Technical Standards and Implementing Technical Standards and is intended to give ESMA and national competent authorities a structured, comparable view of the scale, characteristics and risk profile of EU firms’ exposures to recognised third-country CCPs. ESMA states that the design aims to support the broader EMIR 3 monitoring framework while limiting incremental burden by reusing information already available through existing reporting channels where possible. The consultation covers the reporting framework, templates and reporting format, with responses due by 12 October 2026. No implementation or application date has been announced; ESMA will assess feedback and prepare a Final Report after the consultation. Firms clearing through recognised third-country CCPs should treat this as a medium-impact forward-planning item because it may create a new annual data production, validation and governance process.

What Changed

newProposed annual reporting framework for recognised third-country CCP activity

The source does not identify an implemented harmonised ESMA template or format for this annual reporting framework.

New

ESMA proposes draft RTS and ITS to establish a harmonised approach once implemented.

newScope of reporting population

No implemented reporting population is specified in the consultation announcement for this new framework.

New

Clearing members and clients using recognised third-country CCPs are the population ESMA identifies for the proposed reporting obligation.

newSupervisory data objective

ESMA indicates that the new framework is intended to improve supervisory visibility, implying existing channels do not provide all required information in a structured format.

New

The proposal focuses on the scale, characteristics and risk profile of EU firms’ exposures to recognised third-country CCPs.

newTemplates and reporting format under consultation

Final reporting templates and technical format have not yet been adopted.

New

Stakeholders may comment on the proposed framework, templates and format until 12 October 2026.

modifiedUse of existing reporting information

The announcement does not specify a prior burden-reduction approach for this reporting framework.

New

The consultation frames the proposal as aligned with ESMA’s simplification and burden-reduction agenda.

Business Impact

Who is affected

Directly affected

clearing members and clients that clear transactions through recognised third-country CCPs.

Indirectly affected

EU risk, treasury, clearing operations, regulatory reporting, compliance, data governance teams, recognised third-country CCPs, clearing brokers, delegated reporting providers and technology vendors supporting clearing or regulatory reporting data.

Jurisdictions

European Union, EEA firms subject to EMIR where applicable, Third-country CCP jurisdictions to the extent EU firms clear through ESMA-recognised CCPs

Business processes

Annual clearing activity reporting, Third-country CCP exposure monitoring, Clearing member and client onboarding/reference data maintenance, Regulatory reporting data sourcing and reconciliation, Risk and concentration reporting governance, Consultation response management

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

Proposed annual EMIR clearing activity report for recognised third-country CCPsThird-country CCP clearing activity inventory and exposure registerAnnual clearing data reconciliation control between internal books, clearing broker data and existing regulatory reportsConsultation response tracker for draft RTS, ITS, templates and formatRegulatory reporting change impact assessment for EMIR clearing data

Field	Validation rule
Recognised third-country CCP	The proposed framework concerns clearing activity conducted through CCPs recognised by ESMA under EMIR.
Type of financial instruments or non-financial instruments cleared	EMIR Article 7d states that annual reports shall specify the type of financial instruments or non-financial instruments cleared.
Average values cleared over one year	EMIR Article 7d states that annual reports shall include average values cleared over one year.
Union currency and asset class	EMIR Article 7d specifies that average values are to be reported per Union currency and per asset class.
Scale, characteristics and risk profile of exposures	ESMA states that the proposed framework aims to give authorities a structured overview of the scale, characteristics and risk profile of EU firms’ exposures to recognised third-country CCPs.

Recommended Actions

7 suggested next steps· derived from source analysis

1
AI generatedStep 1 of 7
identify all recognised third-country CCPs used directly or through clearing brokers and map accountable business owners for each clearing relationship.
2
AI generatedStep 2 of 7
compare the proposed annual data needs against existing EMIR, clearing, risk and treasury datasets to determine what can be reused and what may require new sourcing.
3
AI generatedStep 3 of 7
assess whether current systems can aggregate clearing activity annually by recognised CCP, instrument type, Union currency and asset class.
4
AI generatedStep 4 of 7
review the consultation paper, draft RTS, ITS, templates and format, and submit evidence-based feedback by 12 October 2026 where the proposal creates data gaps or operational burden.
5
AI generatedStep 5 of 7
establish a provisional data-quality and reconciliation control for third-country CCP clearing data before final rules are issued.
6
AI generatedStep 6 of 7
monitor ESMA’s Final Report and any subsequent adoption of RTS/ITS before committing to full technology build.
7
AI generatedStep 7 of 7
brief compliance, risk, operations and clearing desks that this is not yet effective law but may become a recurring annual reporting obligation.

Timeline

consultation deadline

Oct 12, 2026

Deadline for stakeholders to provide feedback to ESMA on the reporting framework, templates and format.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Official news / consultation announcementEuropean Securities and Markets AuthorityDate not specified
ESMA consults on reporting framework for clearing activity at recognised third-country CCPs ↗
https://www.esma.europa.eu/press-news/esma-news/esma-consults-reporting-framework-clearing-activity-recognised-third-country
Interactive Single Rulebook / primary regulatory textEuropean Securities and Markets AuthorityDate not specified
EMIR Article 7d - Information on clearing activity in CCPs recognised under Article 25 ↗
https://www.esma.europa.eu/publications-and-data/interactive-single-rulebook/emir/article-7d-information-clearing-activity
Official supervisory webpageEuropean Securities and Markets AuthorityDate not specified
Third-Country CCPs ↗
https://www.esma.europa.eu/central-counterparties/third-country-ccps

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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