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EACH Response: Annex to Guideline on REMIT transaction reporting – Reporting of energy derivative transactions under REMIT and EMIR

EACH broadly supports ACER’s objective of providing a clear and coherent framework for the
interaction between REMIT and EMIR reporting requirements. In particular, EACH welcomes
the stated objective of avoiding unnecessary costs and administrative burdens and of
aligning REMIT reporting, to the extent possible, with the reporting frameworks established
under EU financial market legislation. EACH also acknowledges that the proposal has no direct
new reporting impact on CCPs, nevertheless we would like to point out that EMIR data and
related data-quality indicators could have indirect relevance for regulators.

EACH however considers that a number of points would benefit from further clarification to
ensure that the final guidance does not inadvertently create duplicative reporting obligations
for CCPs or uncertainty as to the respective responsibilities of CCPs, OMPs, market participants
and trade repositories.

Read the full response here.

EACH Response: Bank of England’s consultation on central counterparty resolution execution and resolvability outcomes – September 2026

The key messages that EACH would like to convey with this consultation response are the following:

  • Resolution should build on existing CCP recovery arrangements and be proportionate.
  • UK statute rather than amendment of individual CCP rulebooks.
  • A pro-rata approach is a good starting point, but should not be mandatory.
  • Need for clear boundary between CCP recovery powers and Bank resolution powers.

EACH Response: Financial Conduct Authority & Bank of England Joint Vision – Tokenisation for UK Wholesale Markets – July 2026

EACH calls for technology-neutral regulation to unlock the benefits of tokenisation
 
EACH has responded to the Financial Conduct Authority (FCA) and Bank of England’s Joint Vision for Tokenisation in UK Wholesale Markets, welcoming the initiative as a timely step in providing clarity for financial markets. We particularly emphasise:
  • The support the FCA and Bank of England’s vision
  • That tokenisation creates opportunities via tokenised collateral, digital cash and DLT to improve collateral mobility, settlement efficiency and cross-border operations.

  • The importance of a technology-neutral regulation based on the principle of “same risk, same regulatory treatment.”
  • Tokenisation complements existing standards for risk management, netting, settlement finality and operational resilience.
  • Encourages greater international interoperability and alignment between UK, EU and global initiatives.

EACH Response: CPMI-IOSCO Margins & PQD implementation – June 2026

EACH supports global consistency in implementing margin transparency standards
EACH has responded to the CPMI-IOSCO consultation on updated guidance and public disclosures for implementing initial margin proposals. EACH welcomes the guidance as an appropriate global standard and highlights the importance of maintaining international consistency and avoiding regulatory gold-plating. We particularly emphasise:
  • The importance of the CPMI-IOSCO guidance as an appropriate global standard.
  • Consistent implementation across jurisdictions
  • The benefits of historical stress events over hypothetical scenarios in margin simulators.
  • That both CCPs and clearing members have a role to play in providing margin transparency.

EACH Response – CPMI-IOSCO consultation “FMIs’ management of general business risks and general business losses: Further guidance to the PFMI” – February 2026

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